ML20086T994
| ML20086T994 | |
| Person / Time | |
|---|---|
| Issue date: | 02/29/1984 |
| From: | Hebdon F NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | |
| References | |
| NUREG-1022, NUREG-1022-S01, NUREG-1022-S1, NUDOCS 8403070121 | |
| Download: ML20086T994 (58) | |
Text
_ -_-_-
NUREG-1022 Supplement No.1 Licensee Event Report System Description of System and Guidelines for Reporting U.S. Nuclear Regulatory Commission Office for Analysis and Evaluation of Operational Data pa a' coq e'
hDR l 840229 U
1022 R PDR
"b Yb -
F~'
~'
y %.k.n. Q ^ j u & : " ^ -%. '
. : 13
~:
- ~ ',:.':.o : '
- k (
~
,9 l,.,'
4 S
+y
'4 b
)
..h.
.. C)
,Q
?y-e NOTICE S'3 y(p *
'~.;
..?
/
Availability of Reference Materials Cited in NRC Publications
{
Most documents cited in NRC publications will be available. from one of the following sources:
M.,s y.
[;.J 1
(
- 1. The NRC Public Document Roorre,1717 H Street, N.W.
C
?
Washington, DC 20555 o
..g
- 2. The NRC/GPO Sales Program, U.S. Nuclear Regulatory Commission, Q ;,
Washington, DC 20555 i.'.
- c r;;
- 3. The National Technical information Service, Springfield, VA 22161 f p, y
h Although the listing that follows represents the majority of documents cited in NRC publications, g,..
A.,
it is not intended to be exhaustive.
f
.) -
Referenced documents available for inspection and copying for a fee from the NRC Public Docu-L;
- v. ',
ment Room include NRC correspondence and interna' NRC memoranda; NRC Office of Inspection hU and Enforcement bulletins, circula:s, information notices, inspection and investigation notices; Licensee Event Reports vendor reports and corresponder.ce; Commispon papers; and applicant and C. 2 ;
c
'i licensee dccuments ard correspondence.
% '.'[,
y The following documents in the NUREG series are available for purchase from the NRC/GPO Sales
. ?.
O Progu m: formal NRC staff and contractor reports, NRC-sponsored conference proceedings, and 4
..J NRC booklets and brochures. Also available are Regulatory Guides, NRC regulations in the Code of d
L Federal Regulations. and Nuclear Regulatory Commission issuances.
.y
- 4 Documents available from the National Technical Information Service include NUREG series
[d(
,[,.
reports and technical reports prepared by other federal ager.cies and reports prepared by the Atomic
[1 Energy Commission, forerunner agency to the Nuclear Regulatory Commission.
34 Y'
Documents available from putdic and special technical libraries include all open literature items, YY such as boo (s, journal and periodical articles, and transactions. Federal Register notices, federal and y.'[
- 5 state legislation, and cengressional repot ts can usually be obtained from these libraries.
\\
Documents such as theses, dissertations, foreign reports and translations, and non-NRC conference AD.? '
- (
proceedings are avalable for purchase from the organization sponsorin9 the publication cited.
- QI y.
- [
Single copies of NRC draf t reports are available free upon written request to the Division of Tech-1 F
nical Information and Docuroent Control, U.S. Nuclear Regulatory Commission, Washington, DC is F
20555.
?. %.
.~
+
- L-Copies of industrv codes and standards used in a substantive manner in the NRC regulatory process
?
I~
are maintained 'at the NRC Library, 7920 Norfolk Avenue, Bethesda, Maryland, and are available YD 0
there fo' reference use by the public. Codes and standards are usually copyrighted and may be purchased from the originating organization or, if they are American National Standards, from the
- .q y
American National Standards institute,1430 Broadway, New York, NY 10018.
7eW pi.
3-
.x{g 3
- T
- 1. '
y.
y GPJ Pnnted copy price. 4L50.
$f
-4 *. g.J.j O:M?
b&
m;.
a t'p re J'"
}~
~
. ;.. ger -
[,
. -).
j
/ y,($f jl-y (..
{.
'., [
.... '. ' i,..fi.[
.,,.b.
.,,:.e - :
,s
...s 'u
,..)_
aa
.,a.
a_
. ~*
. y7 1
..~,g
NUREG-1022 Supplement No.1 Licensee Event Report System Description of System and Guidelines for Reporting Manuscript Completed: February 1984 Data Published: February 1984 Office for Analysis and Evaluation of Operational Data U.S. Nuclear Regulatory Commission W:shington, D.C. 20555
/* "%,,,
ABSTRACT On' July 26, 1983, the Commission published in the Federal Register a final rule (10 CFR 50.73) that modified and coalfied the Licensee Event Report (LER) system.
The rule becaae effective on January 1,1984.
In September 1983, the NRC published NUREG-1022 which provides supporting information and guidance that is of interest to persons responsible for the preparation and review of
- LERs, The information contained in NUREG-1022 includes:
(1) a brief dc:cription of how LERs are analyzed by the NRC, (2) a restatement of the guidance contained in the Statement of Consideration that accompanied the publication of the LER rule, (3) a set of examples of potentially reportable events with staff comments on the actual reportability of each event, (4) guidance on how to preoare an LER, including the LER forms, and (5) guidance on submittal of LERs.
Subsequently, during the period from October 25, 1983 to November 16, 1983, the NRC staff held five regional meetings to discuss the scope and content of the LER rule with utility and NRC regional representatives.
During these meetings numerous questions arose and were answered.
This supplement to NUREG-1022 contains a summary of the questions asked and the answers given.
iii
TABLE OF CONTENTS Page A85 TRACT............................... iii
~I.
It4TR00VCTION............................ I
!!. QUESTIONS AND ANSWERS FROM THE LER WORKSHOPS...........
3 III. ADDITIONAL QUESTIONS AND AflSWERS ON 10 CFR 50.72........
33 APPENDIX A - COMPARISON OF 50.72 AND 50.73..............
37 APENDIX B - FEDERAL REGISTER NOTICE.................
45 4
V
I.
INTRODUCTION On July 26, 1983, the Commission published in the Federal Register a final rule (10 CFR 50.73) that modified and codified the Licensee Event Report (LER) system.
The rule became effective on January 1,1984.
In September 1983, the NRC published NUREG-1022 which provides considerable information that is of interest to persons responsibi' for the preparation and review of LERs.
In addition, since the reporting criteria in 10 CFR 50.72, "Immediate Notification Requirements of Significant Events at Operating Nuclear Power Plants," and 10 CFR 50.73 are, in most cases, either identical or very similar, NUREG-1022 is also useful for clarifying the types of events that require immediate notification of the NRC in accordance with 10 CFR 50.72.
The information contained in NUREG-1022 includes:
1.
The LER rule (10 CFR 50.73).
2.
A brief det.ription of how LERs are analyzed by the NRC.
3.
A restatement of the guidance contained in the Statement of Consideration that accompanied the publication of the LER rule.
This guidance explains the intent of the various criteria and requirements contained in the LER rule.
4.
General and specific guidance on how to prepare an LER, including the LER fonns.
Tables of some of the codes needed to complete the LER fonn are also included.
5.
A set of examples of potentially reportable events with stat f corr.ments on the actual reportability of each event.
The descriptions were taken from actual operational events; however, reference to the plant at which the event occurred was removed and on occasion the description of the actual event was altered slightly to illustrate a specific point.
Between October 25, 1983 and November 16, 1983, the NRC staff held five regional workshops to discuss the scope and content of the new LER rule (S0.73) and the revised Emergency Notification rule (50.72).
Numerous questions were asked and answered during these workshops.
This Supplement to
.NUREG-1022 is a.sunnary of the questions asked and the answers provided at the various meetings.
As noted above, the reporting criteria in 50.72 and 50.73 are, in most. cases, either identical-or very similar.
Therefore, the questions and answers in Section II of this Supplement to NUREG-1022 are also useful for clarifying the types of events that require immediate notification of the NRC in accordance with 50.72.
In addition, several questions and answers that pertain only to 50.72 are' included in Section II of this Supplement.
Further, a comparison of the criteria in 50.72 and 50.73 is included as Appendix A.
Finally, a copy of
.the Federal Register notice publishing 50.72 is included as Appendix B.
_ II. QUESTIONS AND ANSWERS FROM THE LER WORKSHOPS 1.0 Paragraph 50.73(a)(2)(1)(A), Shutdowns.
1.1 What is meant by " completion of shutdown"? Is this in terms of operating modes specified in the Technical Specifications or do you have a specific pl6nt condition in mind?
Answer:
" Completion of a shutdown" is the point in time when the Technical Specification requires that the plant be shut down (i.e., the first operating mode reached going down in power, that requires that the reactor be subcritical).
For example, if at 0200 the plant enters a Limiting Condition for Operation (LCO) which states, " restore the inoperable channel to operable status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at least Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />" the plant must be shut down (i.e. at least in Hot Standby) by 2000.
The LER is required if the inoperable channel is not returned to operable status by 2000.
1.2 What about the situation where you have seven days to fix a component or be shut down, but the plant must be shut dcwn to fix the component? Assume the plant shuts dowr., the component is fixed, and the plant returns to power prior to the end of the seven day period.
Is that situation reportable?
Answer:
No.
If the shutdown was not required by the Technical Specifications, it need not be reported.
However, other criteria in 50.73 may apply and may require that the event be reported.
1.3 Suppose that there are seven days to fix a problem and it is likely the problem can be fixed during this time period.
However, the plant management elects to shut down and fix this problem and other problems.
Is an LER required?
Answer: Some judgement is required.
An LER is not required if the situation could have been corrected before the plant was required to be shut down, and no other criteria in 50.73 apply.
The shut down is report-able, however, if the situation could not have been corrected befora the plant was required to be shut down, or if other criteria of 50.73 apply.
- 2.0 Paragraph 50.73(a)(2)(1)(B), Technical Specification Violations 2.1.
Is it correct that I do not have to submit an LER unless I actually reach the end of an LC0 clock?
Answer:
Yes.
For the purpose of this criterion, an LER is not required unless the conditions of the LCO and its associated Action Statement are not met (i.e., are violated) or the plant must be shut down because of a Technical Specification requirement (i.e., "the end of an LC0 clock").
2.2 I thought the LER rule was developed in order to assure that serious events were reportable, yet the criteria seem to be the time windows of the LCOs.
Why is it that time restraints are used so frequently?
e
' Answer:
Since time restraints are measures of significance, the staff believes that violations of LCO requirements (e.g., violation of the " time windows") are serious events.
In addition, the staff believes that any event, operation, or condition that is prohibited by the Tech-1 nical-Specification is sufficiently significant to warrant an LER.
2.3 We beli ave that surveillance testing and redundancy together promise assurance of operability.
Further, we often have 7-day LCOs and we perform surveillance tests on 30-day intervals.
Is an LER required every time we find a problem during surveillance testing?
Answer:
No.
In general, for the purpose of evaluating the reportability of situations found during surveillance tests, it should be assumed that the situation occurred at the time of discovery, unless there is firm evidence to believe otherwise.
For example, if a standby component with a 7-day LC0 is found to be inoperable because it was assemblea improperly during the maintenance conducted 30 days previously, then there is firm evidence that it had been inoperable for the entire 30 days, and an LER is required.
2.4 Most Technical Specifications have some LCOs that do not have Action Statements.
When these LCOs cannot be met, the plant enters what is known as the " Motherhood Clause" (e.g., Section 3.0.3 of the Standard Technical Specifications) which requires that they correct the condition or be shut down within one hour.
If the condition is corrected within one hour (i.e., the plant does not shutdown) is the event reportable?
Answer:
The event is reportable.
Although the Technical Specifications are not violated when a plant enters the " Motherhood Clause" the plant is operating with a " condition prohibited by the plant's Technical Specifications" and an LER is required.
The time limit in the section only allows sufficient time for an orderly shutdown.
2.5 My Technical Specifications require that each Surveillance Requirement or Inservice Testing Requirement be performed within the specified time interval with:
a.
A maximun allowable extension not to exceed 257. of the surveil-lance interval, and b.
A total maximum combined interval time for any 3 consecutive tests not to exceed 3.25 times the specified surveillance interval.
If a Surveillance Requirement is missed, but the error is identified and the Surveillance Requirement completed within the extension limits described above, must an LER be submitted?
Answer:
No.
If you are within the limits specified by the Technical Specifications. (e.g., the limits on allowable extensions are not violated), an LER is not required.
2.6 When we violate license conditions, we are to report immediately with a 14-day written followup.
Does the LER rule include license conditions in addition to Technical Specifications and does it supersede this requirement?
~...
- Answer:
No.
Violations of a license condition that are contained in locations other than the Technical Specifications, are not superseded by the LEP rule and should be reported separately (see question 7.15).
2.7 Procedures are required by our Technical Specifications.
Is a violation of a procedure, no matter how minor, considered to be a violation of our Technical Specifications which would be reportable as an LER?
Answer:
No. Although a failure to adhere to a procedure required by the Technical Specification is a violation of the Technical Specifications, whether it is reportable depends upon if it results in a condition covered by the rule. A violation of a procedure would not be directly reportable unless the operation or condition violated a Technical Specification requirement, or it resulted in an event or condition that is reportable under the criteria of 50.73.
If such an error could happen at other plants and could have serious consequences, you are encouraged to submit a voluntary report.
2.8
% Technical Specifications include a number of requirement; concerning fire protection systems and related plant features.
Do I need to submit an LER on aspects dealing with fire protection?
Answer:
Fire protection systems covered by Technical Specification (e.g.,
through Limiting Conditions for Operation) are within the scope of the LER rule.
Fire protection systems that are not covered by the Technical Specifications are not within the scope.
However, fires that challenge such systems may be reportable under 50.73(a)(2)(iii) or 50.73(a)(2)(x).
(See question 7.15) 2.9 Section 6 of our Technical Specifications has a number of admini-strative requirements such as organizational structure, number of personnel on shift, hours of work, need to approve procedures within 14 days, etc. Must we submit an LER whenever an administrative requirement in Section 6 is not met?
Answer:. Although failure to meet the admf 'i trative requirements of the s
Technical Specifications is a vioLion; whether it is reportable as an LER depends upon if it results in a condition covered by the rule.
If the violation of the Technical Specification results _in operation prohibited by the Technical Specifications, then the event or condi-tion is reportable.
For example, operatiun with less than the required number of people on shift would clearly constitute operation prohibited by the Technical Specifications, or operation with a procedure that had not been properly approved would constitute operation prohibited by the Technical Specifications.
However, i f the requirement is only administrative and does not affect plant operation, then an LER is not required; for example, a change in the plant's organizational structure that has not yet been approved as a Technical Speciff cation change.
__ 3.0 Paragraph 50.73(a)(2)(1)(C).
3.1 I cannot find 50.54(x) [ Referenced in 50.73(a)(2)(1)(C)] in the regulations. What does it say?
Answer:
10 CFR 60,54(x) was published in the Federal Register on April 1,1983 (48 FR is366) with an effective date of June 1, 1983.
This rule generally permits licensees to take reasonable action in an emergency even though the action departs from the license conditions or Technical Specifications if the action is immediately needed to protect the public health and safety.
4.0 Paragraph 50.73(a)(2)(ii), Unanalyzed Conditions.
4.1 At one point, we became aware that our plant could have potentially been in an unanalyzed condition.
But we never operated in that condition and we prevented such operation by administrative proce-dures.
Is that reportable?
Answer:
No.
The event is not reportable if the plant was never in an unanalyzed condition.
However, in reviewing the reportability of each situation, please carefully review all criteria of 50.73 since the situation may be reportable under a different criteria.
4.2 If we update our docket with updated infonnation on the plant design basis or accident analysis and we have an event or condition which was outside the original FSAR but not outside of the updated information; do we have to submit an LER?
Answer:
No.
An LER is not required if the event or condition is within the design or licensing basis as currently docketed and approved by the I
NRC.
4.3 Not all of our activitics are covered by procedures.
Must we submit an LER for all activities not covered by procedures?
Answer:
No.
An LER is required only if an activity is required to be procedurally controlled (e.g., by a license condition or by a licensing commitment such as a commitment to comply with Regulatory Guide 1.33).
5.0 Paragraph.50.73(a)(2)(iii), External Threats.
5.1 For potential threats such as tornados, how close does it have to come before it constitutes an " actual" threat to the plant?
Answer:
The licensee must use engineering judgement to determine if there was an actual threat.
For example, with regard to tornadoes, the decision would be based on such factors as the size of the tornado, and its location and path.
There are no prescribed limits, but in general, situations involving only monitoring by the plant's staff are not reportable, but when preventative actions are taken or if there are serious concerns, then the situation should be carefully reviewed for reportability.
1 I 5.2
' Would a snowstorm that prevents people from entering or leaving
]
the plant be reportable?
Answer:
If the snow significantly hampered personnel in the conduct of their activities, the event is reportable. The licensee must use judgement based on the amount of snow, the extent to which personnel were hampered, the extent to which additional assistance could have been available in an emergency, the length of time the condition exi sted, 'etc.
For example, if the snow prevented shift relief for several hours, the situation would be reportable.
5.3 There was a recent earthquake in New York which we reported to the NRC via the Emergency Notification System (ENS). Thirty days later it was clear that there was no actual threat to the plant.
Is an LER required?
Answer: No. An LER would not be required.
However, the call on the ENS was appropriate because of the potential for further seismic activity, and public interest.
6.0 Paragraph 50.73(a)(2)(iv), ESF Actuations.
6.1 There is a wide range of Engineered Safety Features (ESF) installed in the various plants and not defined for some plants.
Is there a standard list of ESF?
Answer: There is no standard list of ESF.
The criterion is based on each plant having defined systems as ESF (e.g.,in the plant's FSAR).
If there is uncertainty in this regard, the situation should be discussed with your NRC Regional Office.
6.2 My plant.(BWR) has the Rod Block Monitor (RBM) as an ESF.
Do I have to submit an LER every time there is a rod block or other action by the RBM7 Answer:
If the rod block monitor (RBM) is not classified as a portion of the Reactor Protection System (RPS) or as an Engineered Safety Feature (ESF), rod blocks need not be repcrted.
However, if the rod block monitor (RBM) is classified as a portion of the Reactor Protection System (RPS) or as an Engineered Safety Feature (ESF),
rod blocks should be reported.
The licensee may request an exempt'on under 50.73(f) if it can be shown that actuation of this system does not constitute an event of actual or potential safety significance.
-6.3 Two of. our ESF systems, the toxic gas isolation system and a control room isolation system, are highly unreliable and often actuate when not needed (invalid actuation).
Are spurious actuations reportable?
Answer:
Yes.
Spurious actuations of ESF are challenges to the system and are reportable.
6.4
.In our plant, a turbine trip results in starting of the diesel
- generator (s), but does not give a reactor scram.
Since a turbine
. trip can result from a variety of nonsafety-related causes, would the starting of the diesel generators (ESF equipment) be reportable?
Answer:
Yes. Actuation of any ESF is reportable.
6.5 If you get a reactor scram before the plant is critical, is this considered reportable?
Answer:
Yes. All reactor scrans are reportable, regardless of the power level when the trip occurred.
6.6 At times we may get a scram signal while performing surveillance testing.
These particular tests are performed only while the plant is shut down (i.e., they cannot be performed at power). Would such scrams still be reportable?
Answer:
Yes, unless the scram was a recognized part of the test procedure and was ex,,ected.
(See also Question 6.9) 6.7 Often we are in operating modes when automatic scrams are not required to be operable, or parts of the containment isolation system may actuate when the system is not required to be operable.
Are such events reportable as LERs?
Answer: Yes.
Actuations of ESF and RPS are reportable even if they are spurious or unnecessary. However, if the actuation or trip is part of a preplanned sequence, or it is a controlled (e.g. documented) and expected result of the procedure (see question 6.8), it is not y
reportable under this criterion (see also question 6.9).
6.8 When we put steam generators in wet lay-up we always get a scram on l
high level.
Would this scram be reportable?
Answer: No. Because the scram signal is not an actual or spurious protective
)
action, but an expected result of a controlled procedure.
1 6.9 Is the spurious operation of a system that is not required to be operable reportable?
Answer:
If the system is not reqaired to be operable and it has been properly l
removed from service such that it can not perform its intended j
function (e.g., manual discharge valves are shut, breakers are I
open), en a spurious actuation of part of the system (e.g., the pur a rarts but the discharge valve remains shut) is not reportable.
How if the system actuates and performs its intended function, the ion is reportable even if the system is not required to I
be (
al.
L 6.10 When we movt. the mode switch to shutdown, we get an automatic scram.
Are these scrams reportable?
Answer:
If a scram is not required, and is an expected result of plac' g the mode switch to shutdown (i.e. it is part of the normal st ' towr.
l procedure), the scram is not reportable.
u
.g.
I 6.11 Some reactor scrams occur because of the actions of individuals (e.g., an ISC technician).
For example, the plant may scram on low pressure because of a human error even though the reactor pressure is fine.
Are such scrams reportable?
Answer:
Yes.
Spurious or unintended reactor scrans are reportable.
6.12-
.If we get multiple scrams over short periods of time, can they be reported in one LER?
Answer:
Yes. More than one event can be reported in a single LER if the events are related (e.g., same general cause or consequences) and they occurred over a reasonably short length of time, (e.g., several errors during a single startup).
However, LERs are intended to address specific events and plant condition and, thus, the flexi-bility of using one LER to report multiple events should never be used to report unrelated events or as an attempt to decrease the number of LERs.
7.0 Paragraph 50.73(a)(2)(v), Events that Could Have Prevented Fulfillment of a Safety Function.
7.1 Some clarification is needed for events or conditions that alone "could have" prevented the fulfillment of a system safety function.
Answer:
" Events or conditions" generally involve operator actions and/or component failures that could have prevented the functioning of a safety-system.
For example, assume that a surveillance test is run on a standby pump and it siezes.
The pump is dissassembled and found to contain the wrong lubricant.
The redundant pump is disassembled and it also has the same wrong lubricant.
Thus, it is reasonable to assume that the second pump would have failed if it'had been challenged.
However, the second pump and, therefore, the system did not actually fail because the second pump was never challenged.
Thus, in this case, because of the use of the wrong lubricant, the system "could have" or "would have" failed. -
7.2 A number of criteria indicate that they apply to actual situations only 7..d not to potential situations identified as a result of analysis; yet, other criteria address "could have." When do the results of analysis have to be reported?
Answer:
The results need only be reported if the applicable criterion requires the reporting of conditions that "could have" caused a problem.
-However, others have a need to know about potential problems that are not reportable; thus, such items may be reported as a voluntary LER.
7.3 Utilities are not required to analyze for system interactions, yet the rule requires the reporting of events that "could have" happened but did not.
Are we to initiate a design activity to determine "could have" system interactions?
_ _ _ _ _ _ - Answer: No.
Report system interactions that you find as a result of ongoing routine activities (e.g., the analysis of operating events).
7.4 I noticed that Section 50.73(a)(2)(v) uses the Part 100 definition of safety related systems.
What about systems and components that may be classified as "important to safety." Are they included in the scope of the LER rule?
Answer: 50.72 and 50.73 use neither the phrase " safety-related" nor "important to safety" because of the varying interpretation associated with these terms.
The definition of the systems included in the scope of these rules is provided in the rules.
7.5 There are many components, systems, and plant features (e.g., fire stops, cooling fans, room isolations) controlled through Technical Specifications and thus must be considered to be " safety related."
Do you want an LER for all these minor items?
Answer: See question 7.4.
An LER should be submitted whenever an event or condition meets the criteria of 50.73.
Several of these criteria involve engineering judgement, and thus, licensees have the ability and responsibility to determine the reportability based upon the situation and the requirements of the rule.
7.6 How long does safety equipment have to operate in order to fulfill its safety function and what guidelines should be used regarding operator assistance or repair? For example, an operator can adjust the amount of cooling water which might allow a pump to continue to operate.
Answer: A safety system must operate long enough to complete its intended function as defined in the FSAR.
Reasonable operator actions to correct minor problems may be considered, however, heroic actions and unreasonably insightful diagnose:,, particularly during stressful situations, should not be assumed.
In addition, in the FSAR, analysis is pcrformed on how long the system / component is expected to operate without operator action.
7.7 Is an LER required if a system is lost but the safety function can still be met by other systems? For example, we have several systems which can be used to remove decay heat.
If we lose one of these l
systems, but other systems are available to perform the same safety functions, is that reportable?
/.1swer: Yes.
Loss of a safety system function is reportable even if there are other systems that can perform the same function.
However, the LER narrative should discuss other available systems capable of ful-filling the same function.
t l
7.8 My Technical Specifications require that if I have one train of the Stand-By Gas Treatment System (SBGTS) inoperative and if one diesel generator is lost, I must declare the SBGTS inoperative since it would not be available if offsite power is lost for any reason.
Is
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ this considered to be an event that "could have prevented" the ful-fillment of the safety function of a safety system (i.e., is a system inoperable if it is declared inoperable, even though the system is still operational)?
Answer:
Yes.
In general, determining if an event "could have prevented" fulfillment of a safety function, unrelated and independent failures that did not actually occur should not be included.
In this case, the failure of the diesel generator is not unrelated.
With one train of the SBGTS inoperable and the emergency diesel generator inoperable in the other train neither SBGTS are capable of performing their intended safety function.
Therefore, the event would be reportable.
7.9 Previously under LER reporting requirements, we did not have to submit an LER when a problem was found in equipment that was out of service or not required to be operable.
Now it seems LERs will have to be submitted.
Is that true?
Answer:
Yes.
Events or conditions are reportable if they meet one or more of the LER criteria, particularly 50.73(a)(2)(v).
Reporting is required regardless of operating mode or power level.
7.10 Suppose during shutdown we are doing maintenance on both SI pumps.
Since this system is not required to be operational, I assume this situation is not reportable?
I also understand that if something happens that would cause both SI pumps not to be operational at power, that would be reportable.
Is that correct?
Answer: Removing botn SI pumps from service to do maintenance is not reportable if the resulting system configuration is not prohibited by the plant's Technical Specifications.
However, if a situation is discovered during the maintenance that could have caused both pumps to fail (e.g. they are both improperly lubricated) then that condition is reportable even though the pumps were not required to be operational at the time that the condition was discovered.
As another example, suppose the scram breakers were tested during shut-down conditions, and it was found that for more than one breaker, opening times were in excess of those specified, or that UV trip attachments were inoperative.
Such potential generic problems are reportable in an LER.
7.11 My plant has a single train safety system (e.g. High Pressure Coolant Injection). Do I have to submit an LER every time we take this system out of service to perform maintenance on it?
Answer:
No.
You are not required to report the removal of such systems for maintenance if it is done in accordance with the Technical Specifications provisions.
7.12 Often during refueling outages, equipment is valved out in order to perform maintenance. This situation (i.e., valving out the system) would not occur at power.
Are errors associated with these situations (e.g., errors in valve out) reportable?
i Answer:
If the system is required to be operational during refueling, the l
error is clearly reportable. However, if the system is not required to be operational during refueling, the test of reportability is not limited to power operation. Use engineering judgement.
If the situation could not have occurred at power and there are adequate procedures that would have discovered and corrected the situation I
before the plant returned to power, it is not reportable. Howev e r,
if confidence cannot be developed that the situation would have been identified and corrected before the plant returned to power, then it should be reported.
- 7. I'3 There are a number of environmental systems in a plant dealing with such things as low level waste (e.g., gaseous radwaste tanks). Many of these systems are not required to meet the single failure criterion so a single failure results in the loss of function of the system.
Are all of these systems covered within the scope of the I.ER rule?
Answer:
If such systems are required by Technical Specifications to be opera-tional_ then system level failures are reportable.
If the system is not covered by Te'.nnical Specifications and is not required to meet the single failure criterion, then the system does not perform a
" safety function" in the context of the LER rule and failures of the system are not reportable.
7.14 At our plant, RCIC is not a " safety system" in that we assume no credit for its operation in our safety analysis.
Are failures and unavailability of this system reportable?
-Answer:
If RCIC is not considered to be an ESF, then its actuation is not reportable under 50.73(a)(2)(iv).
However, if the plant's safety analysis considered RCIC as a system needed to renove residual heat (e.g., it is included in the Technical Specifications); then its failure is reportable under 50.73(a)(2)(v).
If the RCIC is covered under a Technical Specification surveillance test requirement, then an LER is required under 50.73(a)(2)(i)(B) if the Technical Specifi-cation is violated.
-7.15 There is a section covering prompt reporting as a license condition which requires reporting of fire detection failures.
Are these requirements still present?
Answer:
The LER rule only supercedes the reportable section of Technical Specifications (normally section 6.9.1.8 and 6.9.1.9).
All other reporting requirements remain in ef fect. However, other reporting requirements can be satisfied by the submittal of the LER form, with the content appropriately modified to fully describe the reportable situation.
7.16 We have redundant leak detection systems and features.
At what level would a failure be reportable?
u
Answer:
Failures are reportab1'e at the system level under the loss of function i
criterion.
However, LERs may be required under other LER reporting criteria such as violation of Technical Specification LCOs, or because of potential generic problems and thus, all reporting criteria should be carefully reviewed.
7.17 Please refer-to example C-5 (in Appendix C of NUREG 1022).
Suppose a single failure causes a system to be inoperative, but the single failure'has been analyzed -and found by NRR to be acceptable.
I assume that such a single failure would not be reportable?
. Answer:
The loss of a safety system is reportable.
However, the LER can and
. should discuss any analysis or plant features which address or reduce the safety. significance associated with the loss of the function.
7.18 L Assume there are unrelated component failures in several safety
- systems, kould an LER be required?
-Answer:
No.
An LER would not be required if component failures are truly independent (i.e., apparently random) and unrelated.
-7.19 How should.a plant report a defective component that was delivered, but not installed?
Answer:- A single defective component would not generally be reportable (assuming that the problem has _ no generic implications).
A generic problem or a number of defective coinponents would probably constitute
.a condition that'could have prevented fulfillment of a safety function, and, if so, would be reportable.
Engineering judgement is required to determine if the defects could have escaped detection prior to instal-lation and operation. As a minimum, any generic problem' may be
. reported as a voluntary LER.
In addition, such a condition may be reportable under 10.CFR Part 21.
7.20-
'I notice that loss of relief / safety valve capability is reportable.
- Does this mean that an LER'is required when one valve is inoperative?
_-In addition, suppose you have one pump in a cooling system (e.g.,
chilled water) supplying water to both trains of a safety system, but there'is another pump in standby;.is the loss of the one operating pump reportable?
Answer:
No.
Single, independent (i.e., random) component failures are not s
reportable ~as.LERs if the redundant component in the same system did or would have fulfilled the safety function.
In general, however, such failures are reportable to the NPRD System.
However, if such failures have generic implications, then an LER is to be submitted.
- 7.21 Suppose the wrong ' lubricant was. installed in one safety-related
. pump, but the. pump in the other train was correctly lubricated.
Is this reportable?
Answer:
Engineering judgement is required to decide if the lubricant could have been used on the otLer pump, and, therefore, the~ system function
.x
- -. J would nave been lost.
If the procedure called for testing of the first pump before the maintenance was performed on the second pump and the testing clearly !dentified the error, then the error would not be reportable. However, if the procedure called for the wrong lubricant and eventually, both pumps would have been improperly lubricated, and the problem was discovered only when the first pump was actually challenged and failed, then the error would be reportable.
7.22 Example C-8 indicates that a setpoint drif t problem with a particular switch could be reportable. Would you clarify if setpoint drifts are to be reported if they are experienced more than once?
Answer:
The independent failure (e.g., excessive setpoint drif t) of a single pressure switch is not reportable unless it alone conid hava cancad a system to fail to fulfill its safety function, or is indicative of a generic problem that could have resulted in the failure of more than one switch and thereby cause one or more systems to f ail to fulfill their safety function.
7.23 If an approved plant procedure has a major defect (e.g., it contains a step that would cause a safety systen to become inoperative), but that procedure was never used, would that situation be reportable as an LER?
Answer:
If the procedure was approved for use, the error is reportable; whether or not the procedure was actually used.
If the error was discovered before the procedure was approved, the error is not reportable.
However, the licensee is encouraged to submit a voluntary report if it is likely that other plants may have made, but not discovered, the same error.
7.24 Suppose a maintenance operation is being conducted while the plant is shutdown and the operation would never be performed while the plant was at power.
During the maintenance, a personnel error is made and of fsite power is lost to one or more vital areas.
Is that situation reportable?
Answer:
If the procedure could not be performed at power, and no criteria of 50.73 are met, then the error would not be reportable. However, if the error disclosed a previously unidentified design deficiency that was triggered by the error, or if the error was possible using similar procedures that are performed at power, (e.g., there is a similar procedure that would be performed at power and could have produced a similar error that would have had the same result) then the event would be reportable.
In addition, the event would also be reportable if the offsite power that is lost is required for safety functions when shut down.
7.25 In some systems used to control the release of radioactivity, a detector controls certain equipment.
In other systems, a monitor is present and the operator is required to initiate action under certain conditions.
The operator is not " wired" in.
Are failures of the operator to act reportable?
_ _ _ _ _ _ _ _ _ _ Answer:
Yes.
The operator may be viewed as a " component" that is an integral, and frequently essential, part of a " system." Tnus, if an event or condition meets the criterion specified in 50.73 for reporting, it is to be reported regardless of the initiating cause (i.e., whether an equipment, procedure, oa personnel error is involved).
7.26 Assume an error in v11ving is made so that both trains of a system would have been inoperative.
Would the error be reportable if identified and corrected before the initiation of plant operation?
Answer:
It depends on the situation.
If the error was found by chance or good fortune, then it is reportable.
If the error was found by preplanned actions to assure correct valve lineup, then judgement is needed, but generally the error would not be reportable.
8.0 Paragraph 50.73(a)(2)(ix), Radioactive Releases.
8.1 If I have a release over 15 minutes, do I divide by four to get the rate averaged over an hour? What about releases that occur over an extended period such as 3 or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />?
Answer: For a release that takes less than one hour, normalize the release to one hour (e.g., if the release lasted 15 minutes, divide by four to normalize to I hour).
For releases that lasted more than one hour use the highest release for any continuous 60-minute period (i.e., comparable to a moving average).
8.2 Table 2 of Part 20 provides releases in terms of isotopic related values.
Does the release have to be two times any specific isotope before an LER is required?
Answer: No. Releases of mixtures of radionuclides are treated in accordance with tha " Note to Appendix B" of 10 CFR Part 20.
Paragraph 1 of the
" Note' provides for summing of the fractional maximun permissible concentration (MPC) values for the radionuclides known to be present in the mixture. - Paragraphs 2, 3, and 4 of the " Note" provide concentration limits for cases in which the identity or the concentration of any radionuclide is not known.
Paragraph 5 of the
" Note" provides for conditions under which a radionuclide may be considered not to be present in a mixture for purposes of these cal culations.
8.3 Do the criteria on reportability of radioactivity releases include iodine spike releases?
Answer:
Yes.
8.4 What meteorological data should be used in determining offsite concentrations (e.g., annual average, real time or worst case)?
Answer:. Annual average meteorological data should be used for determining offsite airborne concentrations of radioactivity.
This is to maintain consistency with the Technical Specifications.
, 8.5 What location should be used as the point for release calculation purposes (e.g., unrestricted area as defined by Part 20 or the expanded definition as specified in NUREG 0133 " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants")?
Answer: The expanded definition of an unrestriced area as specified in NUREG 0133 should be used.
This is to maintain consistency with the Technical Specifications.
8.6 What is the impact of the rule on the environmental Technical Specifications (Appendix B)? For example, are the radiological release reporting requirements revised?
Answer:
Appendix B Technical Specifications are not affected by the LER rule.
8,7 Can we use LERs to report environmental LERs?
Answer:
Yes. Check the "Other" block in Iten 11 and type " Environmental" in the space immediately below the "Other" block.
TMet At* ORT e6 ?-TTSO *"a=UANT TO THE R40Uintest4ft Of to Con 9: (ca.ct eae.e m.re e' rae fonow*si till 30 egetbl 20 ass'.)
90.734.H2Hiet 73.71h4 30 4W4 41H4 90 304.H11 90 F34.H2itet 73.7118) 30 4004.H1Hul 90 354.H2) to 734.H2Hval R
A f
to.734.H2HouiHA)
JeftA/
at 4884.H1Meul to 73i.H2H4 un.H2H n.'
Environmental m
HiH.wi
.0n H2H.I 30 est8aH1Het se.734.H3Haell 30.734.H2Hal A few utilities use a separate report numbering system for environ-mental LERs which can sometimes cause problems in terms of duplicate LER numbers.
We request that utilities eliminate the environmental LER numbering system and report them within the standard reporting system clearly delineated as environmental LERs.
9.0 Paragraph 50.73(a)(2)(x), Internal Threats 9.1 I understand that if the guard shack burns down and the fire does not actually threaten the plant, the fire would not be reportable.
Is that correct?
Answer:
Yes. A fire that does not pose an actual threat to the plant is not reportable under 50.73.
However, the fire may be reportable under 73.71.
9.2 What role or importance is the plant mode in trying to determine the significance of internal threats? Can we take credit for being shutdown or must we assume all operating modes?
Answer:
You may consider the plant mode in determining if there was an actual threat to the plant.
However, engineering judgement is necessary on a case-by-case basis.
Do not incorrectly assume that everything that happens while the plant is shutdown is unimportant and not reportable.
I l
~ 9.3 You used an example that a fire in the control room would be reportable.
If that event has been analyzed and found to be acceptable, why is it reportable?
Answer: A Tire in the control room is considered reportable because it poses an actual threat to the plant and significantly hampers site personnel.
To be reportable, the test is whether the plant is actually threatened or personnel are significantly hampered.
A fire does not have to actually damage the plant or totally prevent site personnel from performing duties necessary for the safe operation of the plant to be reportable.
9.4 If we have a fire in.the refueling bridge and we are not moving fuel, would the fire be reportable?
Answer:
No.
If the plant is not moving fuel and the Ire does not otherwise threaten other safety equipment arj does not hamper site personnel, the fire is not reportable.
If the plant is moving fuel, the fire is reportable.
9.5 If we have a fire in the reactor building that forces contractor personnel who are doing a safety related modification to leave, but the fire did not hamper operations personnel or equipment, would that fire be reportable?
Answer:
No.
The fire would not be reportable if the fire was not severe enough that it posed an actual threat to the plant and the delay in completing the modification did not significantly threaten the safe operation of the plant.
l 10.0 Event Reportability - General 10.1 Is there any economic damage level threshold for LER reporting (e.g., any event that results in damage in excess of $100,000)?
Answer:
No.
10.2 Is an LER required if we activate our emergency plan?
Answer:
No, unless the eve't that caused the emergency plan to be activated meets one or more of the criteria in 50.73.
10.3 We are aware that a recent generic analysis of the rod drop accident applicable to our plant indicated that this event would exceed the value given'in the FSAR.
Further, the analysis indicated that the condition was fully acceptable and did not result in a serious threat to the plant.
Is an LER required?
Answer:
The condition would be reportable as an LER if the analyzed rod drop had actually occurred and caused the plant to be in a condition outside the design basis of the plant.
If such an event had not occurred the analysis alone would not be reportable as an LER but may be reportable under other NRC requirements.
If the condition were reported as an LER, then the generic analysis should be discussed and referenced in the assessment of the safety consequences of the event [see.9.73(b)(3)].
11.0 Engineering Judgement 11.1 What is the basis for " engineering judgement?" Does that mean a documented engineering analysis or a judgement by a technically quali fied 'inidvidual?
Answer:
Engineering judgement may include either a documented engineering analysis or a judgement by a technically qualified individual depending on the complexity, seriousness and nature of the event or condition.
A documented engineering analysis is not a requiremer.t as a basis for
'an engineering judgement for all events or conditions, but it would be appropriate for particularly complex situations requiring in-depth analysis.
In addition, although not required by the rule, it may behoove the licensee to record in writing that a judgement was exercised by identifying the individual making the judgement, the
' date made, and 'briefly documenting the basis for this judgement.
11.2 Will the resident inspectors understand these same words regarding
~ he use of engineering judgement?
t Answer:.Yes.
The rule and associated documentation have been discussed in considerable detail with the regional staff and with many of the resident inspectors in order to achieve a consistent interpretation by the NRC as well as licensee personnel.
11.3 What happens if the resident disagrees with the plant management and believes an LER is required?
Answer:. When there'is a difference of opinion, licensees will Oe given a position from the Regional Office.
'12.0 Paragraph 50.73(b), LER Content.
12.1 Suppose that during an event several ESF systems actuate. Am I supposed to describe all actuations in the LER event description?
Answer:
Yes. All aspects of the complete event should be described, even those aspects that, by themselves, would not be reportable.
For
-example, if a random component failure (generally iiot reportable) occurs following a reactor scram (reportable), the component failure should be described in the LER for the reactor scram.
12.2 There have been some events where the trip logic was completed by 4 or 5 ESFs. Does each logic train have to be described in the LER?
i i:
Answer: Yes. The LER is to describe the complete event.
There is no need to
(
-provide redundant -information 'or unimportant details, yet the performance and status of ESF equipment important to defining arai u.iderstar. ding what happened and to determining the potential impli-a'*
c?tions of the. event should be discussed.
o
- _ _ _ _. 12.3 Why can't we just reference pertinent sections of our FSAR?
Answer: First, not all organizations or individuals have access to FSARs.
Second, extensive cross-referencing would be excessively time consuming considering the large number of LERs and large number of reviewers that read each LER.
Third, in many cases the FSAR description may not be sufficiently detailed or up-to-date.
12.4 You indicate that any unique plant features are to be described, yet we may not be aware of the extent to which our plant is unique.
How do you determine what is conventional and what is unique?
Answer: The NPRDS Reportable System and Component Scope Manual and IEEE Std 805-1983, " Recommended Practice for System Identification in Nuclear Power Plants and Related Facilities" both contain drawings of generic systems for PWRs and BWRs.
If your systems differ from the generic design, some explanation would be appropriate.
The length and detail should be a function of the extent of the difference and the significance of the difference in terms of understanding what happened.
12.5 Does the term " reasonable and credible" conditions really refer to normal plant operating conditions or to potential accident conditions?
In addition, do we have to consider additional component failures as
" reasonable and credible" alternative conditions?
Answer:
" Reasonable and credible" alternative conditions may include either normal plant operating conditions, additional component failures, or potential accident conditions depending on the event.
Each licensee is required to assess its operating experience.
In order to deter-mine the safety significance and implications of operating events, consideration will normally be given to the implications of the event under normal alternative operating conditions such as reactor power and mode (i.e. would the event be more severe) and under of f-normal conditions expected to actually occur during the life of the plant.
- The intent of this section is to obtain the results of such routine
' reviews.
It should be noted, however, that 50.73(b)(3) does not prescribe the scope or content of the assessment.
12.6 We now make a conclusion in LERs about the impact on public health and safety from reportable events.
Are we to continue to make such conclusions?
Answer: A conclusion regarding the impact or implication on public health and safety may.be includei as part of your assessment but it is not required.
12.7 What is meant by corrective action?
Is that corrective action to restore the system or component to service, or is that corrective action to prevent recurrence, or is it both?
Answer:
Both.
12.8 Should the LER contain information on any personnel disciplinary action taken as a result of the event?
Answer: The discussion of the corrective action taken may, on occasion, include personnel disciplinary actions.
However, reference by name to specific indiviauals should not be included.
12.9 Would you please clarify or define what is meant by " previous occurrence." For example, is it events with the same cause, the same end-result, the same failures, or the same sequence?
In addition, the definition of a " previous occurrence" becomes important when we attempt to answer why corrective action was not adequate.
Answer:
Previous occurences should include previous events or conditions which involved the same underlying concern or reason why the LER is being written (e.g., the same root cause, or the same failure, or the same sequence of events).
For infrequent events (e.g., fires) a rather broad interpretation should be used (e.g., all fires and, l.
certainly, all fires in the same building should be considered j
" previous occurrences").
For more frequent events (e.g., ESF 1
actuat:cns) a narrower definition may be used (e.g., only those scramr with the same root cause, or only those ESF actuations of the same system and with the same root cause need to be considered
" previous occurrences").
The intent is to identify generic or
}
recurring problems.
In addition, for the benefit of users of LER j
data bases. it would be useful to note reference LERs in the abstract
{
on the fi at page of the LER form.
The abstract is generally 1
included in the data base and, therefore, is more readily available f
to system users.
12.10 In the future when the LER rule is effective, do we have to go l
back and report all previous events that are not now reportable
{
such as scrams?
Answer:
No.
For events and conditions which were not required to be reported previously as an LER, "all previous events" means those events and conditions discovered af ter January 1,1984.
12.11 You require that we list all previous events.
Is it permissible to reference LERs that reference other LERs?
' Answer: Reference should be made to all previous LERs in the subject LER.
This serves to greatly increase the efficiency and effectiveness of the LER reviewing process.
13.0 50.73(c), Revised LERs.
13.1 May a revised LER include only instructions to revise specific parts of the original LER?
Answer: No.
The revised LER must stand alone.
In addition, it would be very helpful if the licensee would indicate in the text on the LER form the revised or supplementary.infonnation.
The revised or supplementary L
.=
_ information could be noted in a manner analogous to amendments for FSARs by placing a vertical line in the margin.
13.2 If we mentioned in the LER that an engineering study is being conducted are we obligated to tell you the results of the study?
Answer:
The results of the study should be reported in a revised LER only if it would significantly change the reader's perception of the course, significance, implications, or consequences of the event; or results in substantial changes in the corrective action planned by the licensee.
13.3 What if I check (Item 11 on NRC-365) two criteria for reportability and later I find that other requirements also pertain, must I resubmit the LER?
Answer:
Yes, a revised LER should be submitted.
13.4 If we submit a voluntary LER and later determine that the event is required to be reported, do we have to resubmit the LER?
Answer:
Yes, a revised LER should be submitted.
14.0 50.73(d), Time Limit for Reporting 14.1 When does the 30-day clock start?
Answer:
The LER must be submitted within 30 days of discovery of the event or condition that is reportable.
14.2 The rule says that events must be reported within 30 days of discovery.
How does tHs vary from event date?
7 Answer:
If the event is clearly defined, give the event date in Item 5 of NRC-366.
For example, if an ESF actuated on 1/15/84, but the actuation was not discovered until a review of the sequence-of-events printout on 1/30/84, the event date should be 1/15/84 and the LER is due on 3/1/84 l
(i.e. 30 days from the discovery date of 1/30/84).
However, if a licensee discovered on 1/15/84 that a design error [ report-able under 50.73(a)(2)(v)] occurred some time in 1982, then the event date should be 1/15/84.
l If the LER is not submitted within 30 days from the event date, explain the relationship between the event date, discovery date, and report date L
in the LER text.
14.3 In the past we have always thought of the event date as the date of discovery; thus, we would not have given an 82 number to an event which occurred in 1982 but was not discovered until 1983.
Does 50.73 change this interpretation?
Answer:
The date used as the first two digits of the LER number (Item 6) should be consistent with the event date in Item 5.
In general, the l
.c
___ event date is the day on which the event occurred.
If the event date is not known or is uncertain, the event date can be the discovery date.
14.4 At times the NRC has proceeded with enforcement action based on plant conditions we should have known about, but did not discover.
In this regard, does the 30-day clock for LERs start with the actual discovery date or from the date we should have known?
Answer:
For LER reporting, the event date is the discovery date if the event date is not clearly defined.
Other interpretations may, at times, be appropriate for enforcement action purposes.
14.5 Suppose a technician sees a problem but a delay occurs before an engineer or supervisor has a chance to review the situation.
When does the clock start and what is the difference between " event date" and " discovery date?"
Answer: The discovery date (which starts the 30-day clock) is the date that the technician sees a problem.
Therefore, for a single event or condition it is possible to have as many as four applicable dates:
1.
The Event Date when the event actually occurred (entered in Item 5).
2.
The Discovery Date when someone in the plant recognizes that the event has occurred (starts the 30-day clock and should be entered in Item 5 if the event date cannot be clearly defined).
3.
The "Reportability" Date when someone decides or " discovers" that the event is reportable.
4.
The Report Date when the LER is submitted (entered in Item 7).
If there is a significant length of time (>30 days) between event date and either the discovery or "repor+. ability" date, the reason for the delay should be discussed in the LER text.
14.6 There were a series of questions involving:
a.
For events that occurred in late 1983 but were not reported until 1984, what format should be used?
b.
For events that occurred in 1983 but were not recognized as report-i able until 1984 and were not reportable under 50.73, what format should be used?
c.
For-events that occurred in 1981 but were not discovered until 1985 as reportable under 50.73, what format should be used?
Answer: 50.73 is ef fective on 1/1/84.
Therefore, events that occur in late 1983 should be reported using the LER requirements and format in effect at the time of the event, even though the report will not actually be submitted until after 1/1/84.
Lvents that were discovered (see question 14.5) in 1983 and before but were not recognized as reportable under the previous LER requi re-ments until after 1/1/84 nust still be reported.
The LER requi rements in effect at the time of the event should be followed and the reason for late reporting should be discussed in the cover letter.
The LER number should be based on the ev ent date.
(See question 14.3)
Events that occurred prior to 1/1/84 that are reportable under 50.73 but are not reportable under the previous LER requirenents r,eed hct be repo rted.
Howev e r, if a '1esign deficiency is discovered after 1/1/H4 and it meets the criteria of 50.73 for reportability such as SU.7 3(a )(2)(v ); it should be reported even though the actual design error was made before 1/l/84, 14./
We have subni tted LERs which have not yet been closed out (open-endo 1).
Suppose that the events for which these LERs were longer reportable under the new LER rule; must we written dre no close out these old llRs?
Answer:
Yes.
14.8 Which f o rtaa t should be used for updating old LFRs after January 1,
1984?
Answer:
Rev 1 sions to past reports should be in the same format as the original report.
.g 14.9 Suppose an event is reportable and we are looking at the cause and another event occurs two weeks later and as a result we di scover a generic problem.
When does the 30-day clock sta rt ?
Answer:
The 30-day clock starts when the condition or events becama report-
- dble, it the first event was reportable even if the second evert had not occurred, then the clock starts at the event date of the fi rs t.
ev e n t.
Howev e r, it the f i rst event was not reportable by itself (e.g., a single diesel failure) but the condi tion became reportable because of the second ev ent (e.g., a second diesel failure which indicates that the condition that caused both f ailures is generic) then the clt ;k starts at the tine when the condition was found to be generic (i.e., the fi rst event did not indi cate a reportable condition ; the second event did).
Thus, the event starts when the condition i s di scov ered.
b$
14.10 What happens if the 30-day period ends on a Sunday or holiday?
- v'
. r s:
Answer:
Reports are due in 30 days but reports mailed en the first working jjkg1 day following the end of the 30 days are acceptable.
c ua?g upy: v
'4.11 What should we do if we korw that a rept rt will be late?
YF[
- A.
Answer:
Discuss the situation with the appropriate Regional Office.
g/j9; 0bhh.
- 4n%-
~
s t'
?6i.!.
.t
.* c
- g N E
b
[
fS:
- . $;{i P
- 5 14.12 Does the LER have to arrive within 30 days or is it acceptable to k
have it signed within 30 days and mailed?
Answer:
The LER should be mailed within 30 days except as r.oted in the E
answer to question 14.10.
14.13 We sometimes test components such as valves and snubbers over a period of several weeks.
During this pe'iod we may discover a number of inoperative components.
Do we kve to submit each failure as an LER or can we submit multiple failures in one LER?
g
[
Answer:
For similar f ailures that are reportable under 20.73 criteria and F
that are discovered during a single test progran or activity, report b
all f ailures that occurred within the first 30 days of discovery of the first failure on one LER.
However, the 30-day clock starts when the first reportable event is di scovered.
State in the LER text (and L
code the information in Items 14 and 15) that c supplement to the LER l
will be submitted when the test is completed.
Submi t a rev i sion to the original LER when the test is completed.
include all the fail-ures, including those reported in the original LER, in the revised LER (i.e., the revised LER should stand alor e).
(See question 21.1) c 14.14 It we are in an outage that lasts 60 days, can we write one LER to report problems during this time period or one LER to be followed s
by supplemental reports?
Answer:
Similar events that are part of the same activity or test program and dre therefore related may be reported as a single LER (see question 14.13).
However, unrelated events or conditions should be discussed f
in separate LERs (i.e., this flexibility should not be used as a mechanism to avoid submitting separate reports of separate events).
g (See question 21.1) s 15.0 50.73(d), Report Copies.
I 15.1 We now have to submit almost 60 copies of LERs.
Has this requi re-ment been changed?
r Answer:
Yes.
50.73 requires only two copies, one to the NRC Document Control Desk and one to the Regional Administrator.
An additiona; copy is L
suggested to the resident inspector and this copy may be required in the future.
f 16.0 Paragraph 50.73(f), Exemptions.
[
16.1 Will exemptions be only generic in nature or can they also be plant specific?
Answer:
Exemptions may be plant speci fic or generic.
However, one of the f
goals of the LER role is a consistent set of reporting requirements that apply to all plants.
Therefore, plant specific exemptions z
would not be issued unless fully justified based on unique plant conditions in order to minimize substantative inconsistencies in the reporting requirements.
[
I s
5
v~
17.0 50.73(g), Technical Speci fication Modi fi. tion.
17.1 1s it important to modi fy our Technical Speci fications before Janua ry 1,1984?
}
Answer:
No.
The Technical Specifications change is purely administrative 7
(i.e. it authorizes removing the superceded sections of the Technical Specifications) and can occur at any time before or af ter January 1,1984.
(See NRC Generic Letter 83-43 dated
~_
December 19, 1983) 17.2 There are sections in our Technical Specifications that have reporting requirements which reference the deleted sections.
What happens if these situations are no longer required to be repocted under 50.73?
.c Sometimes these reporting requirements say to submit a Special Report.
Must we do this if the situation is not reportable as an LER?
Answer:
If the requirener,t references the Technical Specifications sections that ref er to LER reporting (typically 6.9.l.6 and 6.9.1.9) and it Joes not meet any of the criteria in 50.73, the event or condition is no longer reportable.
If the requirement references the Technical Specification section associated with Special Reports (typically 6.9.2) it is still reportable as a Special Repcrt (see NRC Generic Letter 83-43 dated December 19,1983).
17.3 As a result of TMI-2 some additional reporting requi rements were M_
added to Section 3 of the Technical Speci fi cations.
For example, Auxiliary Feedwater flow indicators, and PORV valve position are to 98 be reported within 14 days if inoperative for 7 days.
Does the LER rule supersede these Technical Speci fication requi rements?
Answer:
The LER rule supersedes all reporting requirement s that refer to L
to " Reportable Occurrences", "LERs", or reference the Technical Specificatien section associated with LERs.
All ot her reports (e.g., Special Reports) are still required.
17.4 Does the LER rule supersede past IE Bulletins and Information Notices that either had aew reporting requirenents or interpretation of previous LER requi renents?
Answer:
See questions 17.2 and 17.3.
]
17.5 The Technical Specifications requirements which involve the review of LERs by the Plant Review Committee (PRC) reference the LER If you eliminate t'.;s section, you will eliminate any section.
r requirenent for PRC review.
I am sure this was not intendeo, but how will it be corrected?
Answer:
Generic Letter 83-43 (dated December 19, 1983), which describes how l ~
to remove the LER sections from the Technical Speci fications, also
~f 7 describes how to change the reference associated with PRC review to 50,73.
m
==i.-._
4 j a k
f 18.0 Conforming Amendments to Part 20, and Section 50.36.
7 18.1 Are the modifications to Part 20 and Section 50.36 also ef fective on January 1, 1984?
i Answer:
Yes.
The conforming amendments to Part 20 and Section 50.36 that 7,
were published with 50.73 are also effective on January 1,1984.
[
10.0 Voluntary LERs.
I 19.1 In the past, instead of submitting an LER we have, on occasion, submitted information letters.
Can information-type LER: be sub-A mitted under the "Other" category?
Answer:
Yes.
Please submit information-type LERs (i.e., voluntary LERs) as 1
an LER with "Other" checked in the reporting requirement s block
?
(Item 11 ).
In addi tion, ty,. " Voluntary Report" in the space 1mmediately below the "Other" block.
Do not use information i. ett e rs
}_
to report operational events that do not meet 50.73.
i twee marcar is sueuerreo.unsuamv ro f ue naouine+sa=Ts o* to con i <ca.c..-.., -.< ra. wwa siti so aw eo imH2Hm rsnee no notw n ai.in mi sommm
,wimm ruim
-E 3 4054aHittul 50 MieH21 90 73taH2H.mi OrMEm 'Kaar#> m Aaseert to 4JB4eH1 Hml 90 714eH2eli to F34sH2HvielHal JASA/
{
Voluntary Report o mi.Hi m.,
so rmimm eo vmHan.He' so wn H.i
,wH Ho
.o rmH2H.i l
19.2 Do we have to give a number 'o LERs subr.itted as an optional or voluntary report or for a report which meets other than 50.73 x
requirements?
Answer:
Yes.
19.3 If we start submitting a let of reports under the "Other" category (e.g., voluntary reports) we will have a higher number of LERs.
Will we be penalized by those organizations and individuals that count LERs?
e Answer:
You will not be penalized by the NRC (e.g., as part of the NRC Systematic Assesment of Licensee Performance (SALP) program).
It is recognized that counting LERs is not an accurate or appropriate measure and should not be used as a basis to judge licensee perfor-mance at operating f acilities (e.g., How many setpoint drift LERs equal one LOCA LER?).
In addition, we believe that the submittal of optional reports is a strong indicator of a licensee's commitment to complete reporting and to ef fective use of operational experience and thus worthy of specific credit and mention in any appraisal insolving operational data.
However, the use of the LERs by cther organizations is outside of our control.
m L
.. 19.4 Are there any other reporting mechanisms besides LERs for reporting items or conditions which might prove usef ul that will not result in individuals counting the report as an LER?
Answer:
No.
Reportable information is to be submitted as LERs because there are wel1 established procedures for thei r di stri bution and ent ry i nta computerized data files.
Consequently, there is less chance that the information will be lost or " fall through a crack".
20.0 Special Reports.
20.1 My Technical Speci fications equi re certain Special Rcports (typically described in Section 6.9.2).
Can these reports be submitted using tne LER forms?
Answer:
Yes.
The LER forms may be used to submit Special Reports.
Check the "Other" block in Item 11 of the form, and type "Special Report " in the space immediately below the "Other" block.
When it is elected to use an LER for either a Special Report or a voluntary report, the
~
provisions of 50.73(b) covering the content of the report may not be applicable or appropriate.
Thus, in these activities, the content of the report should be developed to best present the infor, nation associated with che situation being reported.
In addition, if the LER Form is used to submit a Special Report, the report nur'5er should be from the sequence used for LERs.
TMit REPORY 18 gueMITTED PURSUANT TO THE RtoulREMENTS OF 10 CF R $ / Cwa one o, e, o r rne %seeng/ till lzo40:nn 20 40sm s0 nunan >
nnw 30 0.anina
.0 mi.nii
.0 7...la n.i nnm 70 4064.ni nsi 50 Mien 2n 80 734.n2n.d)
OTHE R / Spor % a Absewt
" m. Osi.ni n,e>
~ $I!I,'*"'"' "~'
.0 nwono
.0 n nin..im Ai
[1 - ~,n.i Special Report no.0ei.ni ne.i
.0 ni.nzn.,
.O n..nau u '
- n --
l l
20.2 What about c'oplication of reports between special Reports which are still required as LERs.
For example, in our Tachni cal Speci fi cations,
an ECCS actuation (which is reportable under 50. 73(a )(2)(iv )) requi res a Special Report.
Are two reports required? Also, fire detector i
failures are to be reported as Special Reports for Unit 2 and as LERs for Unit 3.
Can't the same type of event be reported by the same type of report ?
Answe r :
If an event is reportable under 50.73 and is reportable as a Special Report, check the block in Item 11 for the applicable section of 50.73, and check the "Other" block.
Type "Special Report" in the space immediately below the "Other" block.
As noted elsewhere, when using the LER form, the content of the report should depend upon the report-able situation.
TM'S REPORT 13 sueMITTED PURSUANT TO TME REQUIREMENTE 0710 CPR $ (Chere one or inor, ed ene ono ng> it il s
70 4021bl 20 40St.)
90 736.n2ni.I 73 71tti 20 4056.l.1 nd to 3SI.nti 50 734.n2H.I 73.71 tel m Osi.ninni w wi.n2>
e0 ni.nzn i 1
4s,. g ag g 20 4081.niniHi 90 734.n2n0 80 7St.n2n.sainAI JSSA/
>0 0sunins e0 nanan.i
.0 ni.nzn.mne>
]
.0 n=nzw Specia1 Report 30 40si.ni n.i e0 ni.nzn.i 21.0 Appendix J Reports (Leak Rate Test Reports).
21.1 I must perform leak rate testing as required by Appendix J and report the results.
This report seems redundant to LER reporting.
Must I submit both on LER and an Appendix J report or just one and if so which one?
Answer: Although reportable situations may be discovered during a leak rate test, the entire leak rate test is not reportable as an LER, and should be reported separately.
22.0 Part 21 Reports.
22.1 Under Part 21, a vendor that identifies a reportable defect submits a Part 21 report to the NRC, and at the same time may inform each purchaser of the component, service, E c.
If the Part 21 report accurately and completely describes how the defect applies to each plant, then no further reporting by licensees is generally made.
However, if the report does not accurately or completely describe how a defect applies to one or more plants, then each unit submits an LER describing how the defect applies to the sut' ject unit.
How should this practice continue under the new reporting requirements?
Answer: The reporting requirements and procedures for Part 21 have not been changed by 10 CFR 50.73.
If a Part 21 report would have been submitted in the past, it should continue to be submitted.
The LtR form may be used in reporting Part 21 occurrences in which case the "Other" block in Item 11 of the LER form should be checked and "Part 21" should be typed in the area immediately below the "Other" block.
If the defect also meets one of the criteria in 50.73, and the applicable section of 50.73 should be checked in Item 11 and the "Other" block annotated as described above.
wie aspont is sueuertso Puneuant to tua naouintuants or to can 5 tea.ce eae er -.. er me wa-a# iiil M etitt 20 0.(s) 80.734.n2nl.)
73.7, M 30 0 4.ninal X
30 734.n2n.)
717tle) 00 2Blenip 1 gag.g ni n.>
o m ia, n..an.
q
.nin.,
n.iunti un..an nu nin i een.nin.,
m.ian ne Part 21 nin.i n.ian.,
nn.ian.,
l 23.0 Section 73.71 Reports.
l 23.1 I understand we can use the LER to report events reportable under
{
973.71.
However, the reporting period of 73.71 is 5 days and 15 days while the LER is 30 days.
Which time period governs?
-Answer:
Licensees may use the LER forms, but time periods and report content requirements of 73.71 still apply.
It should be noted, however, that the staff plans to change the reporting period of 73.71 to 30 days, s
l 1
1 23.2 Since sabotage events can be reported using the LER form, are there any special instructions for including safeguerds or security information or for the labeling or marking of such information?
Answer:
Events or conditions that are reportable under,73.71 should be sub-mitted using the new LER forms with the appropriate olocks in Item 11 checked.
If the report contains safeguards information as defined in 973.21, the LER forms may still be used, but they must be appropriately marked (i.e., Item 17 of NRC-366A).
Safeguards and security informa-tion should be included only in the text (Item 17) (i.e., safeguards and security information should not be included in the abstract (Item 16)).
In addition. the text should clearly indicate the information that is safeguards or security information.
Finally, the requirements of 973.21(g) must be met when transmitting proprietary information.
23.3 At times, in order to properly describe the details of an event and component failures, it may be necessary to include Proprietary Information.
What provisions have been incorporated to adequately protect Proprietary Information if the LER includes such information?
Answer:
If the LER contains Proprietary Information the LER should be appropriately marked (i.e., Item 17 of NRC-366A).
Proprietary Information should be included only in the text (Item 17) (i.e.,
Proprietary Information should not be included in the abstract (Item 16)).
In addition, the text should clearly indicate the information that is proprietary.
Finally, the requirements of 73.21(g) must be met when transmitting proprietary information.
24.0 Forwarding Letters.
24.1 Is a forwarding letter necessary?
Answer:
Yes.
A forwarding letter signed by a responsible official should be used to submit the LER.
24.2 Is there a prescribed format for the forwarding letter?
Is it act.eptable to show a copy (i.e., a "cc") to INP0?
Answer:
There is no prescribed format for the forwarding letter.
Licensees are permitted and encouraged to include INP0 as a "cc" ca the forwarding letter.
24.3 Can multiple LERs be forwarded by one forwarding letter?
Answer:
Yes.
25.0 LER Form.
25.1 Can we use a facsimile of the form in order to use word processing equipment to prepare the LER?
Answer:
Yes.
However, do not significantly alter the size or general format and layout of the form.
25.2 How do I get LER forms?
Answer:
NRC will provide fort:: free of charge.
Fifty copies of each form have
'been sent to each plant manager.
Additional copies may be obtained free of charge by writing to "NRC/ Publication Services Section, U.S. Nuclear Regulatory Commission, Washington D.C. 20555".
25.3 Is it acceptable to reuse a sequential LER number even if the event date is later than subsequent reports?
Answer:
Yes.
We would prefer that all LER numbers be used (i.e., reuse a sequential number rather than leave holes in the sequence).
If you assign an LER number to a report, but subsequently decide not to issue the report, reassign the number to a subsequent event.
25.4 A situation is discovered in one unit that applies to both units.
How should this be reported?
Answer:
Submit a single LER.
Items 1, 2, 6, 9, and 10 should refer to the lowest numbered nuclear unit.
Item 8 should indicate the other urit(s) affected. The abstract (Item 16) and the text (Item 17) should describe how the event affected both units.
25.5 What about plants that have operating modes such as hot shutdown, cold shutdown, operating, refueling, etc., but no mode numbers?
Are we to put an "N" in the operating mode (Item 9)?
Answer:
Yes.
If the plant does not have numerical operating modes (e.g.
" Mode 5") put an "N" in Item 9 and describe the operating mode in the text.
25.6 Where do we put the model number of failed components?
Answer:
Put the model number of failed components in the text.
25.7 Do we have to report only those component failures within the scope of NPRDS (or EIIS), or any component failure involved with the event?
Answer:
Include in the LER text, and in Item 13 of NRC-366, any component failure involved in the event.
25.8 Is the date of supplemental reports considered firm (i.e., a regulatory commitment) or is it just a target date?
Answer:
The " Expected Submission Date" (Item 15) for supplemental reports is a target / planning date.
It is not a regulatory commitment.
25.9 Is it acceptable just to have an abstract (i.e., describe the entire event in the abstract space)?
. Answer: Yes. However, a detailed description of the event is required such that a knowledgeable reader can understand the complete event. We expect that few reportable events will be so simplistic that &v can be adequately described in 1400 characters.
l l 25.10 Is there a limit to the number of characters or pages in LERs?
Answer:
No.
The abstract is limited to 1400 characters but the text may include as many pages as are needed.
25.11 Is it acceptable to include drawings in the LER text? Must they be on the form? What about photographs?
Is it acceptable to send them with the LER?
Answer: Drawings, figures, tables, photographs, etc. may be included with LERs.
If at all possible, they should be provided on an LER form (i.e., NRC 366A).
In addition, care should be taken to insure that drawings, etc. are of sufficient quality to pennit legible repro-duction and micrographics processing.
Oversized drawings (i.e.,
larger than 81/2 X 11) should be avoided, if at all possible.
1
- - - - - - - - - -. - - - i III. ADDITIONAL QUESTIONS AND ANSWERS ON 10 CFR 50.72 1.0 Words Vs Examples 1.1 It is difficult to instruct an operator how to implement the specific reporting requirements of 50.72.
The regulations are words, yet the explanation is by example.
Would it not have been better to have more examples?
Answer:
It is correct that the regulations do not include examples and may need amplification in plant procedures.
The information contained in this supplementary NUREG does, however, contain specific examples.
Comments on the regulaticns themselves can be submitted at any time and should be submitted where a regulation can be improved or needs to be changed to assure safety.
2.0 Categories of Reports 2.1 There seem to be three categories of reports - 15 minutes to offsite organizations; I hour to the NRC; or as soon as possible after reporting to offsite agencies.
Can you clarify this?
Answer:
Reports should be made as soon as practical and in no case later than the regulatory deadlines.
Dif ferent deadlines are provided so that more time is permitted for events of less safety significance.
3.0 Paragraph 50.72(b)(1)(1)(A) - Initfition of Shutdown 3.1 Maintenance is required on a safety-nlated component and, as a result, the component is not available.
A limiting condition for operation (LCO) is then entered.
In order to fix the problem it is necessary to reduce power but not to shut down. Must we report via the emergency notification system (ENS) when we reduce power?
Answer:
Yes.
If the plant is in a LC0 e'd must reduce power, it should be reported, even though the shutdown was not completed and even though the power reduction may be necessary only to fix a component rather than to meet the requirements of the LC0 to shut down.
4.0 Paragraph 50.72(b)(1)(v) - Emergency Assessment Capability 4.1 What is meant by a major loss of emergency assessment capability?
For example, w;uld loss of the Safety Parameter Display System (SPDS) be reportable?
Answer: A major loss of emergency assessment capability would include those events that significantly impair the licensee's safety assessment capability.
Some engineering judgement is needed to determine the significance of the loss of particular equipment.
Loss of only the SPDS for a short period of time need not be reported, but loss of SPDS and other assessment equipment at the same time may be reportable.
- f. f '.l. $.:.&NW.[ h%&$;' %.?.&j N.&$.%d[ Q 'k's 4lp.&.Q:[.; j_Q n...,X
- ~. r.
v.: y,
- 4
-q
.~;
m n,.
.c n 4.2 What is meant by a major loss of offsite response capability? For 1- ;
5.:.j example, would the loss of one siren.*or a short period of time
}
Y warrdnt making an immediate notification to tha NRC?
v h.
Q Ty.. :
Answer:
A major loss of offsite response capability would include those events that would significantly impair the fulfillment of the
~.s
'I
- -y licensee's approved emergency plan.
Although loss of a single siren 7:D G
for a short period of time is not a major loss of offsite response M
!. W capability, the loss of a large number of sirens or more importantly f[
the loss of the capability to alert a large segment of the population O
for a period of one hour, would warrant an immediate notification.
K t
1.j; '
4.3 In the rule as published in the Federal P.egister, the examples Q
j regarding " loss of emergency assessment capability, offsite response 3
- 7 capability, or communications capability" all deal with equipment 7
.; ; s under the direct control of the licensee. Must a plant notify the M(.
NRC if equipment maintained or owned by others fails and that failure
?(
..l. f degrades offsite response, emergency assessment or communications
- {j
? J.)
capability?
y k:
., g; -
D Answer:
Yes.
If, for example, the alert systems (e.g. sirens), are owned v>k and/or maintained by others, the licensee should take ressonable M
74j measures to remain informed and they must notify the NRC of a large 1l'.
v !.y number of sirens fail (see question 4.2).
As another example, if
.y l# =
a large storm or other event causes roads to be closed and the State L
EG and local governments are rendered incapable of fulfilling their
(.
responsibilities in the emergency plan for the plant, then the NRC g
7i must be notified.
e
=.
n.
y?
)
4.4 Suppose that a plant is doing a surveillance instruction on its
(.
y(:4; undervoltage protection and the first step is to place the security M
'd
,,1 computer and eme gency communications on a back up power supply which p
v.C is a diesel generator.
If the diesel generator f ails and communi-4
.73 cations with local law enforcement agencies are lost for a minute O
jp-D or two until power is transferred back to the normal bus, should P.
- .R this be reported as a loss of emergency communications capability?
~
v.
A momentary loss of emergency communications or offsite response y
v
,.. w Answer:
No.
'f.s.(t capability does not have to be reported.
9 et
- 9;. c O'
5.0 Paragraph 50.72(b)(2)(vi) - Radioactivity Releases T
- $ i hl 5.1 I noted that " inadvertent" releases of radioactive material were 7
v.p" stated in the rule as an example which would require a 4-hour
@DJ.~
notification, irrespective of magnitude, if a news release or i
O.N notification to other government agencies is made.
Is this correct?
e
. [,,6j
.t..,.3.
u.;
Answer: The 50.72 4-hour notification was not for " routine" releases r
Zi although they may be required to be reported to the State.
- However,
- p j,. -
..?. ;';)
- .3-(-
y
..i.
(
- y *.
Q 7
s..-
w.-
j.
-m e maa.m m..y,..y....mn.x g.g, m m 3, n.g
msg
' a " routine" release which subsequently received media attention should be reported to the NRC in accordance with 50.72(b)(2)(vi).
The key statement is ".... event or situation related to the health 1'
and safety...."
Where a State or other government entity has a requirement or agreement with an NRC licensee for routine reporting of other matters, the NRC only requires a report when that matter gets escalated to a " news release" of a " situation."
5.2 If we are required to make routine reports to the Environmental Protection Agency (EPA) regarding routine effluent release data, are we required to make immediate notification to the NRC?
Answer:
No.
Routine reports on effluents need not be reported under the immediate notification requirements.
If, however, there is a particular effluent release that has safety significance, or is expected to generate public, media, or other agency attention as a result of being unusual or abnormal, then an immediate notification to the NRC would be warranted.
5.3 You indicated that some events need not be reported if there is no anticipated press interest.
We may not know whether a press release will or will not be issued within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
What should we do?
Answer: A report should be made within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of a decision to issue a press release.
5.4 Must the plant notify the NRC per 50.72(b)(2)(vi) when the State incident response facility receives an alarm indication coincident with a control room alarm? For example, an ef fluent radiation monitor alarms both in the plant control room and at the remote State center, but the actual radiation release is less than the criteria in 50.72(b)(2)(iv).
Answer:
Several State incident / emergency response facilities receive real time alarm indications coincident with alarm conditions at nuclear power facilities.
For example, a hi-radiation alarm for a gaseous ef fluent radiation monitor would activate alarm indicators at a remote State facility.
The NRC does not consider these alarm indications as notifications to the State by the licensee.
An alarm received at a State facility is in itself not a requirement for notifying the NRC.
In so far as this reporting criteria is concerned,
~]
the licensee need only notify the NRC when the licensee determines that a reportable release has occurred, or believes a real potential exists for interest on the part of the State, the media, or the
[
public, or a press release is being planned.
l APPENDIX A COMPARISON OF 50.73 AND 50.72 50.73(a)(2)(1)(A) The completion of any nuclear plant shutdown required by the plant's Technical Specifications; or (B) Any operation or condition prohibited by the plant's Technical Specifications; or (C) Any deviation from the plant's Technical Specifications authorized pursuant to 50.54(x) of this part.
50.72(b)(1)(1 )( A) The initiation of any nuclear plant shutdown required by the plant's Technical Specifications.
(B) Any deviation from the plant's Technical Specifications authorized pursuant to 50.54(x) of this part.
I l
^
50.73(a)(2)(ii) Any event or co' resulted in the condition of the nuclear power p ng its principal safety barriers, being seriously
,r that resulted in the nuclear power plant beins (A)
In an unanalyzed condit ;on that significantly compromised plant safety; (B)
In a condition that was outside the design basis of the plant; or (C)
In a condition not covered by the plant's operating and emergency procedures.
50.72(b)(1)(ii) Any event or condition during operation that results in the condition of the nuclear power plant, including its principal safety barriers, being seriously degraded; or m"Its in the nuclear power plant being:
(A)
In an unanalyzed condition that significantly compromises plant safety; (B)
In a condition that is outside the design basis of the plant; or (C)
In a condition not covered by the plant's operating and emergency procedures.
50.72(b)(2)(i) lay event, found while the reactor is shutdown, that, had it been found wh;le the reactor was in operation, would have resulted in the nuclear power plant, including its principal safety barriers, being seriously degraded or being in an unanalyzed condition that significantly compromises plant safety, t
r
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 50.73(a)(2)(iii) Any natural phenomenon or other external condition that posed an actual threat to the safety of the nuclear power plant or significantly hampered site personnel in the performance of duties necessary for the safe operation of the nuclear power plant.
- +************************************
50.72(b)(1)(iii) Any natural phenomenon or other external condition that poses an actual threat to the safety of the nuclear power plant or sigr.1ficantly hampers site personnel in the performance of duties necessary for the safe operation of the plant.
50.73(a)(2)(iv) Any event or condition that resulted in manual or automatic actuation of any Engineered Safety Feature (ESF), including the Reactor Protection System (RP...
However, actuation of an ESF, including the RPS, that resulted from and was part of the preplanned sequence during testing or reactor operation need not be reported.
50.72(b)(1)(iv) Any event that results or should have resulted in Emergency Core Cooling System (ECCS) discharge into the reactor coolant system as a result of a valid signal.
50.72(b)(2)(ii)
Any event or condition that results in manual or automatic actuation of any Engineered Safety Feature (ESF), including the Reactor Protection System (RPS).
However, actuation of an ESF, including the RPS, that results from and is part of the preplanned sequence during testing or reactor operation need not be reported.
l
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ 50.73(a)(2)(viii )( A) Any airborne radioactivity release that exceeded 2 times the applicable concentrations of the limits specified in Appendix B, Table II of Part 20 of this chapter in unrestricted areas, when averaged over a time period of one hour.
(B) Any liquid effluent release that exceeded 2 times the limiting combined Maximum Permissible Concentration (MPC) (see Note 1 of Appendix B to Part 20 of this chapter) at the point of entry into the receiving water (i.e., unrestricted area) for all radionuclides except tritium and dissolved noble gases, when averaged over a time period of one hour.
(ix)
Reports submitted to the Commission in accordance with paragraph (a)(2)(viii) of this section also meet the effluent release reporting requirements of paragraph 20.405(a)(5) of Part 20 of this chapter.
- =*********************
50.72(b)(2)(iv)(a) Any airborne radioactive release that exceeds 2 times the applicable concentrations of the limits specified in Appendix B, Table 11 of Part 20 of this chapter in unrestricted areas, when averaged over a time period of one hour.
(B) Any liquid effluent release that exceeds 2 times the limiting combined Maximum Permissible Concentration (MPC)
(see Note 1 of Appendix B to Part 20 of this chapter) at the point of entry into the receiving water (i.e.,
unrestricted area) for all radionuclides except tritium and dissolved noble gases, when averaged over a time period of one hour.
(Immediate notifications made under this paragraph also satisfy the requirements of paragraphs (a)(2) and (b)(2) of 20.403 of Part 20 of this chapter.)
42 -
. 50.73(a)(2)(x) 'Any event that posed an actual threat to the safety of the nuclear power plant or significantly hampered site personnel in the performance of duties necessary for the safe operation of the nuclear power plant including fires, toxic gas releases or radioactive releases.
50.72(b)(1)(vi) Any event that poses an actual threat to the safety of the nuclear power plant or significantly hampers site personnel in the performance of duties necessary for the safe operation of the nuclear power plant. including fires, toxic gas releases, or radioactive releases.
4
[
L
^t
_ - - 50.73 - No comparable requirement.
- ,e*****************
50.72(b)(1)(v) Any event that results in a major loss of emergency assessment capability, offsite response capability, or communications capability (e.g., significant portion of control room indica-tion, Emergency Notification System, or of fsite notification system).
50.72(b)(2)(v ) Any event requiring the transport of a radioactivity contaminated person to an offsite medical facility for treatment.
50.72(b)(2)(vi) Any event or situation, related to the health and safety of the public or onsite personnel, or protection of the environment, for which a news release is planned or notification to other government agencies has been or will be made.
Such an event may include an onsite fatality or inadvertent release of radioactive contaminated materials.
45 -
APPEfiDIX B Federal Register Notice for 10 CFR 50.7?
a
Federal Regisler / Vol. 48. No.108 / Monday, August 29, 1983 / Rules and Regulations 39039 Com:aission. Washington, D.C. 20555; Telephone (301) 492-4973.
SUFFLEssENTARY INFORMATION:
I. Background On February 29,1980, the Commission amended its regulations without prior notice and comment to require timely and accurate licensee reporting of information following significant events at operating nuclear power reactors (45 FR 13434). The purpose of the rule was to provide the Commission with immedicte reporting of twelve types of significant events where immediate Commission action to protect the public health and safety may be required or where the Commission needs accurate and timely information to respond to heightened public concern. Although the rule was made immediately effective, comments were solicited. Many commenters believed the rule was in socne respects either vague and ambiguous or overly broad.
Af:er obtaining experience with notifications required oy the rule, the Commission published in the Federal Register a notice of proposed rulemaking on December 21,1981 (46 FR 81894) and invited public comment. The proposal was made to meet two objectives: chan8e 10 CFR 50.54 to implement Section 201 of the NRC's 1980 Fiscal Year Authorization Act and change 10 CFR 50.72 to more clearly 10 CFR Part 50 specify the significant events requiring licensees to immediately notify NRC.
Immediate Notification Requirements The problems and issues which this i
of Significant Events At Operating rulemaking e ! dresses and the solutions l
Nuclear Power Reactors that it provides can be summarized in l
fise broad areas:
AGENCv: Nuclear Regulatory Commission.
- 1. Authorization ActforFYM A m Hc al rule Section 201 of the Nuclear Regulatory sussesARY:'Ihe Nuclear Regulatory Commission Authorization Actfor Commission is amending its regulations Fiscal Year 1980 (Pub. L 96-295) which require timely and accurate provides:
informarion from licensees followin8 (alSection 103 of the Atomic Energy Act of significant events at commercial nuclear 1954 is amer.ded by adding at the end thereof power plants. Experience with existing the following new subsections: f. Each license requirements and public comments on a leeued for a utilization facility under this proposed r* vision of the rule indicate section or section SQ4b. shall require as a that the exisucg regulation should be conditbn thereof that in case of any accident amended to clarify reporting criteria and which could result in an unplanned release of to require early reports only on those quantities of fission products in excess of matters of value to the exercise of the allowsMe limits for nonnel operation established by the Commission. the licensee Commission's responsibilities. The shallimmediately so notify tne Commission.
amended regulation will clarify the list Violation of the condition prescribed by this of reportable events and provide the subsection may.in the Commluion's Commission with more useful reports
- iscretion constitute grounds for license regarding the safety of operating nuclear tevocation. In accordance with section 187 of power plants.
this Act, the Commission shall promptly EFFECTtVE DAtt:Janusry 1,1964.
amend eachse for a unzadon facWy issued unde
- this section or section 104b.
FOR PUftfl4ER INFOfthiATION CONTACT:
which is in effect on the date of enactment of Eric W. Weiss. Office of Inspection and tMe subwet;on to include the provisions Enforcement. U.S. Nuclear Regulatory mquired under this subsection.
30040 Federal Register / Vol. 48. No.168 / Monday. August 29, 1983 / Rules and Regulations Accordingly, this rulemaking includes prepare detailed written reports for Conditions officenses if Sa54) en amendment to 13 CFR 50.54 that certsin events (48 FR 33850).
A few commenters said that the would add an appropriate notification
( 801 inotton Mth itcensee 8
" Commission already has the ability to requirement as a condition in the Emergency Plan enfcrce its regulations and does not operating license of each nuclear utilleation facihty licensed under section The current scheme for heensees' naad to incrporate the items as now 103 or 104b. of the Atomic Energy Act of emergency plans includes four propmed fato conditions oflicense/'
1954, as amended. 42 U.S.C. 2133. 2134b.
Emergency Classes. When the licensee The Con mission has decided to Dese facilities generally are the declares one of the four
- ncy prmnulgate the propoacd revision of commercial nuclear power facilities Classes, it must report th se i 50.54. " Conditions of Licenses,"in which produce electricity for public Commission as required by 3 50.72.The order to satisfy the intent of Congress as consumption.Research and test reactors lowest of the foerEmergency Classes.
expressed in Section 201 of the Naclear are not subject to the license condition Notification of Unusaal Event, has Regulatory' Commission Authorization as they are licensed under section 104a.
resulted in unnecessary einergency Act for Fiscal Year 1980. This Act and or 104c.of the Act.Under the declarations. Events that fall within the its relationship to i 50.54 are discussed amendment to 10 CFR 50.54, licensees Unusual Event class have been neither in detail in the Federal Register notice falling tmder sections 103 or 104b. would emergencies in themselves nor for the proposed rule (46 m 61894).
be requirad, as a condition of their precursors of more serious events that respectis aperating licenses, to notily are emergencies.
Coordination \\Vith OtherReporting the NRU Immediately of events specified Although changes to the definition of Requirements (Fino1 Rule f Sa72/
in to CFR 50.72.
the Emergencg Classes are not being Seven commenters said that the NRC
- 2. Unnecessary Repons
",' fngsche ahoald coordinate the requirements of 10
,p et w uld u timately CFR 50.72 with other rules. with Several categories of reports required eliminate ** Unusual Event" as an NUREG-0654. " Criteria for Preparation by 5 50.72 are not useful to the NRC.
Emergency C'ess requiring notification Among these cate,gories are reports of.
canbe adopted consistent with this rule. and Evaluation of Radiological
~
worker injury, small radmactive A proposed rulemaking which would Emergency Response Plans and releases, and minor security problems.
redefine the Emergency Classes in Preparedness in Support of Nuclear For example, reports are presently il 50.47 is in preparation and may soon Plants." and with RegulatoryiLide 1.16.
required if a worker onsite experience be published for public comment.This
" Reporting of Operating Information chest pains or another lijness not related final rulemaking makes possible the
.." Many of these letters identified to radiation and is sent to a hospital for elimination of " Unusual Event" as an overlap. duplication, and inconsistency evaluation; or if the vent stack monitor emergency dass without further among NRC's reporting requirements.
< moves upward a few percent yet amendment of 8 50.72 by including in The Commission is makirq;a radiation levels remain 100.000 times the category of non Emergencies the concerted effort to ensure consistent below technical specification limits: or if subcategory of "one-hour reports."
and coordinated reporting requirements.
the security computer malfunctions for a i Vogue or Ambijuous Reportir;g The requirements contained in the revision of 10 CR 50.72 ere being few *ninuter.
Criterio His rulemaking eliminates such coordinated with revision of 6 50.73, reporting requirements from 150.72 and
%e reporting criten.a in i 50.72 have i 50.55(e). Appendix E of Part so, in general clarifies and narrows the been revised in order to clarify their i 20.402. I 73.71. and Part 21.
scope of reporting. However. revision of scope and intent.%e enteria were
' Part :"3 of the Commission's regulations revised for the pmposed rule and in Citing to CFR 50.72 os a Sosisfor is necessary to resolve all problems with response to public comment.The Notification (Fina/ Rule f 5a72(a)(d//
security reports-
" Analysis of Comments" portion of this A few commenters objected to citing j
Federal Register notice describes in i M2 as a beds when making a 1 Terminology. Phrusing, and Reporti f more detail specdic exarnples of 4
telephene notification. ne letters of Threshold' chaapesin wordingintended to comment questioned the purpose. legal De various sections of 10 CFR 30 eliminate vagueness or ambiguity.
ff
- t. a d burden on the licensee.
have diferent phrastas, turnmology.
II. Andyeis d Commenh The Commission does not believe that sad threshMds in the reporting wineria.
Even when rn different meaning is Twenty letters of oo. ament were it is an unnecessary burden for a
. intended a change in woriling can cause received in nesponse to the Federal licensee to know and identify the basis Register notice pubbsbed on December for a telephone notific.ition required by confusion.
21.1981140 m stape).Me twenty I W2. %ese have been many his rolemaking has been carefully I' 'I C8"" '*"ved, the vast occasions when a licensee could not tell written to use terminology. phrasing.
maMy its d 20) were fresa atibties the NRC erbether the telephone and reporting thresholds that are either owniEE #f Operating nuclear power notification was being made in Identical to or sisnitar to those in 5 50.73.
plants. This Federal Register motnoe accordance with Technical l
whenever possible. Other conformies described the ymposed revision ef to Specifications,10 CFR 50.72, some other ameedsments to parts 2s. 21. 73, and in CFR 5052. " Notification of Significant requirement, or was just a courtesy call.
I l 50.f.S and Appendix E of part 50 are Events." and to CR 5"4. " Conditions Unless thelicensee can identify the under development.
of Licenses." A deanssion of the more nature of the report,it is difficult fo..the As a parallel ac:ivity to the significant comments foHows:
NRC to know what significance the preparation of 130.72, on July 28. Iss2.
licensee attaches to the report. and f the Cumumlasion has published a
- *N'*"8""""* *" "*M* 8" becomes more difficult for the NRC to 1.icenaea Event Report (IE.R) Rule
($ 5033l which requires licsneees for
@,M7MMNw respond quickly and properly to the operating nuclear power plants to wnhempen.nc mass event.
J
_ }
Federal Register / Vo! 48. No 168 / Monday. August 29 1983 / Rules und ReSuons 39041
~
/m nedeote Shutdos.n /FmalRule airborne concentrations decrease or oc < u rrmg a t oper u t m i < <,, power f5072/b//1J/i))
until respiratory protection deuces are plants A de.dhne shra : o. ona hour Several commenters objected to the unlized They noted that these esents was not adopted te a the use of the term. "immediate shutdownf are fairh commoa and should not be Commission does no: ws t to mieriere saying that Technical Specifications do rep riable unless the mquired w.th the op ro:o
. 2 wh not use such a term naastion affects the ent re facihty or a an acudent or 1%
u.c f ast few De term is used m some but not all ma; r pad f it.
mocal mma s Technical Specifications Consequenth.
The Commission agrees The wordmg Therefore Lw or %& comunts the Commission has revised the cnten n has been changed to and its esperwna me w rm include only those events which estabhshed a tour hour report ' es was repor*ing cntenon m question Tne final sigmhcantly hamper the abihty of site suggested rule requires a report upon the trutsetion P*""**E'"""*""
of any nuclear power plant shutdown necessary for safe opershon Reac for Semm /F'-
L~,
required by TecJtrucal Speafications One commenter was concerned that s 50 72/b;t2noli Plant Operutmg and Emergency events oocurring on land owned by the Several wn_memer< sm J inat reotter Procedures /Fmol Rule f So 72/b//1)/n))
utihty adjacent to its p: ant might be scrams. particularly those ar rams below rep rtaWe his is not the mten of this power operation. should noi require M
reportmg requirement The NRL} l' Several contmenters said that the notificatmn of the NRC witfun one hour reporting cntena should not make sa@ te and notf plant and in response to these comtr.ents, in<
c nceine w reference to plant operstmg and pes nne n u
y a si Commismon had changed the reportmg emergency procedures because ivihes on land a It would take operators too long to deadlme to four hours How es er. the en to pia decide whether a plant condit2on was Commjnsion does not regard reactor covered by the procedures.
Eaphcit Threats /F,nolRule scrams as "non-es enu, as stated n b The procedures cover esents that f So 72/b//11/vi//
some letters of comment Infonnation related to reactor scrams has ' cen are not of concern to the NRC. and A few commenters said ibut the intent o
'8'
- 'dentifytag safety-r-lated c The procedures vary from plant to of the term. "exphcitly threetens." was plant unclear. Those commentmg w *1dered problems. The Commission agrees that Whde the plant operstmg persennel what level chreat was invoh ed The
' ur hours e an appropnate deadhne for erm. "exphcitly threatens. ' has been thu rrportmg requirement because these should be famihar with plant e
procedurea. it is true that procedures deleted from the fir al role Inttead. the events am not as mortant to very from plant to plant and cover final t ile refers to "any event that poses immediate aden as o n me other
" " "'8 events other than those which an actual threat to the safety of the compromise plant safety. However, the nuclear power plant' ll 50 72(b)(1)(vi)}
Rodmortn e Re/cose 7Errshold /Fmo/
wordmg of the reportmg cnteria has and gives examples so that it is clear the Rv/r 4 50 72/b//21/ny!
been modified (I so 724b)(1)tii) m the Commission is interested in real or Several commenters said that the final rule) to narrow the reportable actual threats as opposed to threats threshold of 25% of showabie hmits for events to those that gignificantly without credibihty compromise plant safe +y.
radioactive releases was too low for Notwithstanding the fact that the
&dicotmn Timing /Fmel Ro/c one hour reportmp procedures vary from plant to plant the f Sa72(b)(2//
Based upon these comments and its Commission has found that this cntenon The commenters generahj had two expenence, the Commisson has results m notifications indicative of points to make regardmg the timing of changed the threshold of reportmg to menous events The narrower. more reports to the NRC. First. the comments those releases exceeds two times Part specific wordmg will make it possible supported notificatwn of the NRC after 20 concentrations when everaged over a for plant operstmg personnel to identify appropriate State or local agencies have penod of one hour This wiu ehmmate reportable events under thetr specific been notined Second, two com.nenters reports of releases that represent operating procedures.
requested a new four-to six hour report neghgMe nak to the pubbc category for events not warrantig a The Commusion has found that low Buddmg Evocuation lFmo/ Rule report with one bour.
level radioactive releases below two f Sa 72$14)(inJJ Allowing more time for arportmg times Part 20 concentrations do not. m Ten commenters said that the some non Emergency events would themselves, warrant immediate proposed i 50J2(b)(6)(iii) regarding lessen the impact of reporting on the radiological responst "any accidental, unplanned or individuals responsible for raiatsining This paragraph regures the reportmg uncontrolled release resulting in the plant in a safe condition. limiting of those events that cause an unplanned evacuation of a buildm6" was unclear the extension of the deadline to four or uncontrolled reirase of a significant and counterproductive in that it could hours ensures that the report is made ainoont of radioactive matenel to offsite cause reluctance to evacuate a buildmg when the information is fresh in the areas. Unplanned releases should occur Many of these commenters stated that minds of those involved and that it is mfrequently. however. when they occur, the reporting of in-plant releases of more likely to be made by tho.c at least moderate defacts have occurred radioactivity that require evacuation of involved rather than by others on a later in the safety design or operational individual rooms was inconsistent with shift.
control estabbshed to avoid their the ge tral thrust of the rule to require Other. more significant non occurrence and. therefore these events reposting of significant events. They Emergency events and all declarations should be reported.
noted that minor spills, small gaseous of an Emergency murt contmue to be Personnel Rodmortive Cor:tammatwn waste releases, or the disturbance of reported within one hour. The one-hour contaminated particulate matter (e g..
deadhne is necessary if the Commissioa (AnolRole f Sa72(bf/1)(v)J dust) may oil require the temporary is to fulfillits responsibihties dunng and Several commenters objected to the evacuation of individual rooms until the following the most senous events use of vague terma sec.h as " extensive
39042 Federal Register / Vol. 48. No.168 / Monday. August 29, 1983 / Rules and Regulations onsite contamination" and "readily from a license condition or technical the containment). Examples of this type removed"in one of the reporting criteria specification.
of situation include.
of the proposed rule.
Porograph M72(b):1)(ii).
(a) Fuel cladding failures in the Based on this comment. new criteria encompassing events previousl>
reactor. or in the storage pool, that have been prepared that use more classified as Unusual Events and some exceed expected values or that are specific terms. For example, one new events captured by proposed unique or widespread, or that are criterion requires reporting of "Any i 50.72(b)(1) was added to provide for caused by unexpected factors, and event requiring the transport of a consistent, coordinated reporting would involve a release of significant radioactively contaminated person to an requirements between this rule and 10 quantities of fission products CFR 50.73 which has a similar provision.
(b) Cracks e.nd breaks in the piping or offsite medical facility 'for treatment."
Experience with telephone notifications Public comment suggested that there reactor vessel (steel or prestressed made to the NRC Operations Center should be similarity of terminology, concrete) or major components in the suggests that this new criterion will be phrasing and reporting thresholds primary coolant circuit that have safety between i 50.72 and i 50.73. The intent relevance [ steam generators, reactor easily understood.
of this paragraph is to capture those coolant pumps, valves, etc.).
til. Paragraph-by Paragraph Explanation events where the plant including its (c) Significant welding or material of the Rula principal safety barriers, was seriously defects in the primary coolant system.
Pomgmph 50.72/of reflects some degraded or in an unanalyzed condition.
(d) Serieus temperature or pressure consoli'lation of language that was For example, small voids in systems transie.nts, repeated in various subparagraphs of designed to remove heat from the (e) Loss of relief and/or safety valve reactor core which have been previously functions during operation.
the propcsed rule. h. general, the intent shown through analysis not to be safety (f) loss of containment ' unction or and scope of this paragraph do not significant need not be reported.
integrity including:
reflect any change from the proposed liowever, the accumulation of voids that (i) Containment leakage rates rule.
could inhibit the ability to adequately exceeding the authorized limits, Several titles were added to this and remove heat from the reactor core.
(ii) loss of containment isolation subsequent sections. For example, particularly under natural ctreulation valve function during tests or operation.
paragraph ".o.72(b) is titled "Non-conditions.would constitute an
( lions of ma n steamisolatiorf Emergency Events" and it has two unanalyzed condition and would be valve function during test or operation.
subparagraphs: (b)(1). titled. "One.Ilons reportable. In addition, voiding in Reports" and (b)(2). "Four.11our instrument lines that results in an (iv)less of containment cooling or Reports." ne events which have a one-erroneous indication causing the hour deadhne are those having the operator to misunderstand the true po58"
.h'A potential to escalate to an Emergency condition of the plant is also an enc mpassing a portion of proposed Cl***' The f "'.h "' deadli"' I' unanalyzed condition and should be 50.72(b)(2), was reworded to correspond explained in the analys.is of paragraph reported.
- to a similar trovision of10 CFR ne Commission recognizes that the
,i 50.73(a)(2)(iii). Making the requirements Pasmph 50.72(b)(1)i )(A) requires licensee may use engineering judgment of to CFR 50.72 and 50.73 similar in repormg of The initiation of any and experience to determine whether an language increases the clarity of these nuclear plant shutdown required by unanalyzed condition existed. It is not rules and minimizes confusion.
TechnicalSpecifications. Although the intended that this paragraph apply to ne paragraph has also been Intent and scope have not changed, the minor s ariations in individual reworded to make it clear that it applies change in wording between the parameters, or to problems conceming only to acts of nature (e g., tomadoes) proposed and final rule is intended t a ngle pieces of equipment. For example, and extemal hazards (e.g.. railroad tank clarify that prompt notification is at any time, one or more safety-related car explosion). References to acts of required once a shutdown is initiated.
components may be out of service due in response to public comrnent, the to testing maintenance, or a fault that aabotage have been removed, since term 'immediate shutdown that was has not yet been repaired. Any trivtal these are covered by I 73.71. In addition.
threats to personnel from intemal used in the proposed rule is not used in single failure or minor error in hazards (e.g., radioactivity releases) that the final rule.The term was vague and performing surveillance tests could unfamiliar to those licensees who did produce a situ 1ition in which two or hamper personnelin the performance of not have Technical Specifications using more often unrelated. safety-grade necessary duties are now covered by the term.
components are out-of. service.
Paragraph 50.72(b)(1)(vi). nis paragr6ph his reporting requirement is intended Technically, this is an unanalyzed covers those events involving an actual to capture those events for which condition. However, these events should threat to the plant from an extemal Technical Specifications require the be reported only if they involve condition or natural phenomenon, and initiation of reactor sht tdown %is will functionally related components or if where the threat or damage challenges provide the NRC with early waming of they significantly compromise plant the ability of the plant to continne to safety significant conditions serious safety.When applying engineering operate in a safe manner (including the enough to warrant shutdown of the judgement, and there is a doubt orderly shutdown and maintanance of plant.
reganling whether to report or not. the shutdown conditions).ne licensee Pomgmph 50.72(bf/1)(i)/B) was added Commission's policy is that licensees should decide if a phenomenon or to be consistent with existing should make the report.
condition actually threatens the plant.
requirements in i 50.54(x) and the Finally, this paregraph also includes For example, a minor brush fire in a existing n 50.72(c) as published in the material (e.g., metallurgical or chemical) remote area of the site that is quickly Federal Register on Acril 1,1983 (48 FR probler.s that cause abnormal controlled by fire fighting personnel and.
13966) which require the licensee to degradation of the principal safety as a result, did not present a threat to notify the NRC Operations Center by barriers (i.e., the fuel cladding, reactor the plant should not be reported.
telephone when the licensee departs coolant system pressure boundary, or However, a major forest fire,large-scale
,1
Feder:1 R:gister / Vol. 48. No.168 / Monday. August 29, 1963 / Rules and Regulations 39043 flood. or major earthquake that presents
- 5. Plant monitors necessary for is possible. because these personnel will a clear threat to the plant should be accident assessment.
have a better knowledge of the reported. As another example, an Ptrmp uph M72(b/(1//vif.
circumstances associated with the vent.
industnal or transportation accident encompassing some portions of the Reports made within four hours of the which occura near the site creatmg a proposed il 50.72(b) (2) and (e), has event should make this possible while plant safety concem should be been revised to add the phrase.
not imposing the more rigid one hour reported.
" including fires, toxic gas relear as, or requirements.
Paragmph 50.72/b/(1//iv).
radioactive releases." This addition The reporting requirement m encompassing events previously covers the " evacuation" portion'of porograph M 72(b//2//// is similar to a classified as Unusual Events. requires paragraph 50.72(b)(6)(iii) of the proposed requirement in i 50.73. Moreover. except the reporting of those events that result rule. This change tn wordmg for the final for referring to a shutdown reactor, this in ePher automatic or manual actuation rule was made in response to pubhc reporting requirement is also similar to of the ECCS or would have resulted in comments discussed above.
the "One-liour Report" in activation of the ECCS if some While paragraph 50.72(bl(1)(iii) of the 150.72(b)(1)(ii). flowever this paragraph cotoponent had not failed or an operator I nal rule primanly captures acts of applies to a reactor in shutdown action had not been taken.
nature, paragraph 50.72(b)(1)(vi) condition. Events within this For example,if a valid ECCS signal captures other events, particularly acts requirement have less ureency and can were generaten by plant conditions. and by personnel.The Commission bebeves be reported within four hours as a "Non-the opt rator were to put all ECCS this arrangement of the reporting cnteria Emergency."
pumps in pull.to-lock though no ECCS in the final rule lends itself to more Pomgmph 50 7?/b//2//ii/ (proposed discharge occurred, the event would be precise interpretion and is consistent 5072{b)(5))is made a "Non-Emergency" reportable.
with those pubic comments that n response to public comment. because A " valid signal" refers to the actual requested closer coordination between the Commission agrees that the covered plant conditions or parameters the reporting requirements in this rule events generally have slightly less satisfying the requirements for ECCS and other portions of the Commission's urgency and safety significance than initiation. Excluded from this reporting regulations-those events included in the "One4 tour requirement would be those instances This provision requires reporting of Reports "
where instrument drift, spurious signals, events. particularly those caused by acts The ir5 tent and scope of this reporting human error, or other invalid signals of personnel, which endanger the safety requirement have not changed from the caused actuation of the ECCS. liowever. of the plant or interfere with personnel proposed rule ~1his paragraph is such events may be reportable under in performanm of duties necessary for intended to capture events during which other sections of the Commission a safe plant operations.
segulations based upon other details; in The licensee must exercise some an ESF actuates. either manually or automatically, or fails to actuate. ESFs particular, paragraph 50.72(b)(2)(ii) judgment in reporting under this section.
requires a report within four hours if en I or example, a small fire on site that did are provided to mitigate the gg g
Engmeered Safety Feati.re (ESP) is not endanger any plant equipment and ac*uated.
that did not and could not reasonably be they should work properly when called Experience with notifications made expected to endanger the plant. is rot upon and (2) they should not be O
F.d PP#b pursuant to i 50.72 has shown that reportable.
Commission is mierested both m. events events involving ECCS discharge to the Paigraph 50.72/b//f/ of the proposed vessel art generally more serious than rule a os spht into g M72(b//i/(ii/ and where an ESF was needed to mitigate ESF actuatior.s without discharge to the f M72/5//2/(if in the fmal rule in order the consequences of the esent(whether sessel.11ased on this exptrience, tne to permit some type of reports to be or not the equipnwnt performed Commission has enade th's reporting made within four hours instead of one properly) and events where an ESF criterion a "One.Ilour Repo-t "
hout because these reporta have less operated unnecessarily.
Porgmph M7.*/b/////n /.
safety significance. In terTns of their
" Actuation" of multichannel ESF encompassing. events prev;ously combmed effect, the overallintent and Actuation Systems is defined as classified as Unusual Events covers scope of these paragraphs have not actuation d enough channels to th*e events that would impair a changed from those in the proposed rule. complete the minimum actuaton logic.
licenat e% ability to deal with an Smce the types of events intended to be Therefore single channel actuations, accident or emergency. Nvtifying the captured by this reporting requirement whether caused by failures or otherwise.
NRC of these events may permit the are similar to i 50.72(b)(1)(ii). except are not reportable if they do not NRC to take some compematin,t that the reactor is shut down. the reader complete the minimum actuation logic.
measures and to more completely assess should rti ? to the explanation of Operation of an ESF as part of a the consequences of such a loss should i 50.72(b)(t){ii) for more details on planned test or operational it occur during an accident or intent.
evolution need not be reported.
emergency.
Porngraph M72(b//2/ Although the flowever,if during the test or Examples of events that this criterion reporting uitena contained in the evolution the ESF actuates in a way that is intended to cover are those in which subparagraphs of 5 50.72(b)l2) were in is not part of the planned procedure.
any of the following are not available:
the proposed rule, in response to public that actuation should be reported. For
- 1. Safety parameter display system comment the Commission established example,if the normal reactor shutdown (SPDS).
this "Non Emergency" category for pmcedure requires that the control rods
- 2. Emergency Response Facilities those events with slightly less urgency be inserted by a manual reactor trip. the (EPTs).
and less safety significance that may be reactorinp need not be reported.
- 3. Emergency communications reportert within four hours instead of However,if conditions develop during facilities and equipment including the one hour.
the shutdown that require an at.tomatic Emergency Notification system (ENS).
The Commission wants to obtain such reactor trip. such a reactor trip should
- 4. Pubhc prompt Notification System reports from personnel who were on be reported. The fact that the safety ncluding sirens.
shift at the time of the event. when this
39044 Fe&r:1 Register ' Vol. 48 No.168 / Monday August 29, 1983 / Rules and Regulations analysis assumes that an ESF will service to perform maintenance, and the criterion. For example, the Commission acturte automatically during an event Technical Specifications permit the is increasingly concerned about the does not eliminate the need to report resulting configuration, and the system effect of a loss or degradation of what th;t actuation. Actuations that need not or component is returned to service had been assumed to be nonessential be reported are those initiated for within the time limit specified in the inputs to safety systema. Therefore, this re: sins other then to mitigate the Technical Specifications, the action paragraph also includes those cases consequences of an event (e.g., at the need not be reported under this where a service (e.g.. heating.
discretion of the licensee as part of a paragraph. However, if, while the ventilation, and cooling) or input (e.g.,
pl:nned procedure).
component is out of service, the licensee compressed air) which is na:essary for identifies a condition that could have rel5ble orlong-term operation of a Pomgraph 50.72(b)(2)(iii)(proposed prevented the system from performing safety system is lost or degraded. Such 50.72(b)(4)) has been revised and its intended function (e.g., the licensee loss or degradation is reportable,if the simplified.
finds a set of relays that is wired proper fulfillment of the safety function The words "any instance of personal incorrectly), that condition must be is not or can not be assured. Failures Error, equipment failure, or discovery of reported.
that affect inputs or services to systems design or procedural inadequacies" that it should be noted that there are a that have no safety function need not be cppeared in the proposed rule have been limited number of single-train systems
- reported, replaced by the words " event or that perform safety functions (e.g., the Finally, the Commission recognizes condition." This simplification in High Pressure Coolant injection System that the licensee has to decide when language is intended to clarify what was in BWRs). For such systems, loss of the personnel actions couM have prevented c ccnfusing phrase to many of those single train would prevent the fulfillment of a safety function.For wh2 commented on the proposed rule.
fulfillment of the safety function of that example, when an individual improperly Als2 in response to public comment, this system and, theiefore, must be reported operates or maintains a component, that reporting requirement is a "Non-even though the plant Technical person might conceivably have made Em rgency" to be reported within four Specifications may allow such a the same error for all of the functionally hours instead of within one hour.
condition to exist for a specified length redundant components (e s.,if an his paragraph is based on the of time. Also,if a potentially serious individual inconectly calibrates one casumption that safety.related systems human error is made that could have bistable amplifier in the Reactor cnd structures aro intended to mitigate prevented fulfillment of a safety Protection System, that person could the consequences of an accident. While function, but recovery factors resulted in conceivably incorrectly calibrate all paragraph 50.72(b)(2)(ii) applies to the error being corrected, the error is bistable amplifiers). However, for an cctual demands for actuation of an ESF, still reportable.
event to be reportable it is necessary paragraph 50.72(b)(2)(iii) covers an ne Commission recognizes that the that the actions actually affect or cv:.nt where a safety system could have application of this and other paragraphs involve components in more than one f;iled to perform its intended function of this section involves a technical train or channel of a safety system. and because of one or more personnel errors, judgment by licensees. In this case, a the result of the actions must be including procedure violations; techmcal judgment must be made undersirable f um the perspective of equipment failures; or design, analys,s, whether a failure or operator action that protecting the health and safety of the i
f brication, construction, or procedural disabled one tram of a safety system public.The components can be d;ficiencies.The event should be could have, but did not, affect a functionally redundant (e.g., two pumps reported regardless of the situation or redundant tram. lf so, this would in different trains) or not functionally condition that caused the structure or constitute an event that "could have redundart fe.g., the operator correctly prevented the fulfillment of a safety stops a punap in Train "A" and. instead system to be unavailable.
his reporting requirement is similar function, and, accordingly, must be of shutting the pump discharge valve in t a or.e contained in i 50.73. thus reported.
Train "A " he mistakenly shuts the reflecting public comment identifyira If a component fails by an apparently pump discharge valve in Train "B").
the need for closer coordination of random mechanism,it may or may not reporting requirements between i 50.72 be reportable if the functionally Paragraphs 50.72(b)(2)(iv)[ proposed r nd i 50.73.
redundant component could fail by the 50.72(b)(6)) has been changed to clarify This paragraph includes those safety same mechanism.To be reportable it is the requirement to report releases of systems designed to mitigate the necessary that the failure constitute a radioactive material. The parsgraph is consequences of an accident (e.g.,
condition where there is reasonable similar to i 20.403 but places a lower containment isolation, emergency doubt that the functionally redundant threshold for reporting events at filtration). Hence. minor operational train or channel would remain commercial power reactors. The lower cvents such as valve packing leaks, operational untilit completed its safety threshold is based on the s,gmficance of i
which could be considered a lack of function or is repaired. For example. if a the breakdown of the licensee's program control of radioactive material, should pump fails because of improper necessary to have a release of this size, not be reported under this paragraph.
lubrication, there is a reasonable rather than on the significance of the System leaks or other similar events expectation that the functionally impact of the actual release.The may, however, be reportable under other redundant pump, which was also existing licensee radioactive material j
paragraphs.
improperly lubricated. would have also effluent release monitonng programs i
nis paragraph does not include those failed before it completed its safety and their associated assessment cases where a system or component is function. then the failure is reportable capabilities are sufficient to satisfy the
]
removed from service as part of a and the potential failure of the intent of 50.72(b)(2)(iv).
planned evolution,in accordance with functionally redundant pump must be Based upon public comment and a cn appioved procedure, and in reported.
reevaluation by the Commission staff, cccordance with the plant's Technical Interaction between systems, the reporting threshold has been Specifications.For example,if the particularly a safety system and a non-changed from "25%" in the proposed rule licensee removes part of a system from safety system, is also included in this to "2 times" in the final rule and has 1
Fed:r:I R: gist;r / Vol. 48. No.108 / Monday. August 29. 1983 / Rules and Regulations 39045 i
been reclassified as a "Non-Emergency" respond because of media or public IJst of Subjects in 10 CFR Part 50 1]be reported within four hours instead attention.
^"
I" cf within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Porogruph 5a72(c)(proposed 50.72(c))
pmenHon. Inc rp ration by reference, Also this reporting requirement has has remained essentially unchanged Interg vernmental relations. Nuclear been changed to make a more umform from the proposed rule, except for requirement by referring to specific addition of the title " Followup p wer plants and reactors. Penuity.
release enteria instead of referrmg only Notification" and some renumberia Radiation protection. Reactor sitinR ta Technical Specifications that may This paragraph is intended to provide entgia. Reporting and recordkeepm,t v:ry somewhat among facihties the NRC with timely notification when "4"'" **"'*
Dis reporting requirement is intended an event becomes more serious or Pursuant % he Aeomi. Energy Act of to capture those events that may lead to additionalinformation or new analyses 1954 as amended, t.u Energy cn accident situation where significant clanfy an event.
Reorganization Act oi Mr/4 as amended.
cmounts of radioactive material could D a paragraph also permits the NRC and section 552 and 553 of Title 5 of the be released from the facility. Unplanned to ma ntain a continuous United States Code, the following releases should occur infrequently; communications channel because of the amendments to Title *10. Chapter 1. Code fb.at ces mo erste defects have need for continuing follow-up of Federal Regulations. Part 50 are informati n or because of published as a document subject to occurred in the safety design or telecomunmications problems.
codification.
operational control utablished to avoid Geir occurrence and, therefore, such IV. Regulatory Anuysis PART 50-DOMESTIC LICENSING OF svents should be seported.
e Commiss n has epare PRODUCTION AND UTILIZATION NorTnal operating limits for g
on.
radioactive effluent releases are based FACILITIES on the limits of to Cm Pact 20 which The analysis examines the coats and benefits of the Rule as considered by the 1.The authority citation for Part 50 establishes maximum annual average concentration in unrestncted areas. nis Commission. A copy of the regulat 0 contmues to read as follows:
reporting requirement addresses analysis is available for inspection and concentrations averaged over a one copying for a fee at the NRC Public Authority:3ecs 103.104.181.182,183.186, Document Room.1717 H Street. NW..
18R 6a Stal 938. 937. 948. 953. 954. 955. 95e. a s hour period and represents less than 0.1% of the annual quantities of Washington, D C. Single copies of the amended. sec. 234. a3 Stat 1244. as amended r:dioactive materials permitted io be
- , may be obtained fram Eric W.
142 U.S C 2133. 2134. 2201. 2232. 2233. 2236.
retessed by 10 CFR Part 20.
Weiss. Ofhce of Inspection and 2239,2282); secs. 201. 202, Zoe. 88 Stat.1242.
Pbrograph 5a72(b//2f(rf(proposed Enrorcement. U.S. Nucgear Reguiatory 1244.1248. as amended 142 U S.C 5841. 5842.
rule 50.72(b)(7)) has three changes. The Commission. Wa shington. D.C. 20555.
Section 50 7 also issued under Pub.1. 95-first elimmates the phrase " occurring Telephone (301) 492-4973.
801. sec.10. 92 Stat. 2951 (42 U.S C. 5851) onsite" because it is implied by the V, Paperwork Reduction Act Statement Sections so sa. 50 91 and 50 92 also issued scope of the rule.He second replaces under Pub L 97-~415. 98 Stat. 2073142 U S C.
" injury involving radiation" with The information collection 2239) Secnon so 7s also issued under sec.
" radioactively contaminated person."
requirements contained in this final rule 122. 66 Seat 939 (42 U.S C. 2152) Sechons his change was made because of the have been approved by the Office of so no-50 at also issued under sec ia4. sa Sist.
difficulty in def' ing inicry due to Management and Budget pursuant to the m
954. as amended (42 U.S C. 2234) Sections radiation, and more importantly.
Pap rwork Reduchon Act. Pub. L M-511 50100-50102 also issued under sec 186. ea because 10 CG Put 20 captures eventa (clearance number 31564011).
Stat. 955 (42 U S C. 223el.
involving radiation exposure.
VI. Regulatory Flexibility Certification l'or the purposes of sec 223. f.8 Stat. 958. as The third change, in response to amended (42 U S C 2273). Il 50 to (=1. Ibl.
public comment, was Io make this in accordance with the Regu!st 7 and (c). 50 44. 50 46. 50 4s. 50 54. and 50 oolal reporting requirement a four hour Flexibihty Act of 1980. 5 U.S.C. 005(b)*
are issued under sec.181b. 68 Stat 948. as notification,instead of one. hour the Commission hereby certiks that amended (42 U.S C. 2201(bl). Il 50101b) and notification. Die change was made this regulation will not have a (c! and 50 54 are issued under sec. teii, es because these events have slightly less significant economic impact on a Slat 949 as amenkd (42 U.S C. 2201D)]. and safety significance than those required substantial number of small entities.
Il so S5(ej. 50 50(bl. 50 70. 50 71. 50 72. ar,d to be reported within one hour.
His final rule affecn electric utihties so 7s are issued under sec 181o. se Stat. eso.
Parogmph 5a72ibf/2f(vsf(not in that sre dominant in their respective
,, amended l42 U.S C 2201(oji proposed rule) besides covering some service arens and that own and operate events such as release of radioactively nuclear utibration facihties licensed
- 2. A new paragaph (2)is added to contaminated tools or equipment to the under sections 103 and 104b. of the 150.54 to read as follows:
Atom,c Energy Act of 1954, as amended.
public that may warrent NRC attention.
i clito covers those events that would,not he amendments clarify and modify 9 50.54 Condmons of 16censa.
otherwise warrant NRC attention except presently existing notification for the interest of the news media, other requirements. Accordingly, there is no govern:nent agencies, or the public. In new. significant economic impact on (t) Each licensea with a uniization terms of its effect on licensees. this is these licensees, nor do the affected facihty licensed pursuant to sections 103 not a new reporting requirement licensees fall within the ecope of the or104b.of the Act shallimmedietely becsuse the threshold for reporting definition of "small entities" set forth in notify the NRC Operations Center of the injuries and radioactive release was the Regulatory Flexibility Act or withm occurrence of any event specified in much lower under the proposed rule.
the Small Business Site Stendards set i 50.72 of this part.
His criterion will capture those events forth in regulations issued by the Small previotsly reported under other criteria Business Administration at 13 CFR Part
- 3. Section 50.71is revised to read as when such events require the NRC to 121.
follows:
39046 Fed:rsi Rrgistir / Vol. 48. No.168 / Monday. August 29, 1983 / Rules and Regulations i so.72 immamate noemessen (C)In a condition not covered by the when averaged over a time period of requiremente for opweting nucoser power plant's operating and emergency one hour.
Procedures.
(B) Any liquid effluent release that (a) Genern/ Requimments.' (1) Each (iii) Any natural phenomenon or other exceeds 2 times the limiting combined nuclear power reactor under i 50.21(b) external condition that poses an actual Max mum permissible Concentration er I 50.22 of this part shall notify the threat to the safety of the nuclear (MpC)(see Note 1 of Appendix B to Part NRC Operations Center via the power plant or significantly hampers m of this chapter) at the point of entry Emerttency Notification System of:
site personnelin the performance of "C'i 8
(i) ne declaration of any of the duties necessary for the safe operation I",'
d a
a 1 a ionuclides Ermergency Classes specified in the of the plant.
except tritium and dissolvej noble licensee's approved Emergency Plan; sor (iv) Any event that results or should (ii) Of those non-Emergency events have resulted in Emergency Core gases, when averaged over a time period specified in paragraph (b) of the section.
Cooling System (ECCS) discharge into of one hour. (Immediate notifications (2)If the Emergency Notification the reactor coolant system as a result of made under this paragraph also satisfy System is inoperaus e, the licensee shall a valid signal.
the requirements of paragraphs (a)(2)
. (v) Any event that results in a major and (b)(2) of I 20.403 of Part 20 of th,s i
m ke the required notifications via commerical telephone service, other loss of emergency assessment cnapter.)
d:dicated telephone system, or any capabilitt, offsite response capability or (v) Any event requiring the transport other method which will ensure that a communications capability (e.g..
of a radioactively contaminated person report is made a6 soon as practical to significant portion of control room to en offsite medical facihty for the NRC Operations Center :
indication. Emergency Notification treatment.
(3) The licensee shall notify the NRC System, or offsite notification system).
(vi) Any event that poses an actual (vi) Any event or s,tuation. related to i
immediately after notification of the thmet to the ufety of the nuclear the health and safety of the public or cppropriate State or local agencies and poweglant or significantly hampers site onsite personnel. or protection of the not later than one hour after the time the personnelin the performance of duties environment. for which a news release licensee declares one of the Emergency necessary f r the safe operation of the is planned or notification to other Cla w s nu er pownplant inchiding fires. toxic government agencies has been or will be a report under (4) When maki7this section, the gas releases. or radi active releases-made. Such an event may include an regraph (a)(3) 0 (2) Four*Nour Reports. If not reported onsite fatality or inadvertent release of censee shallidentify:
under paragraphs (a) or (b][1) of this radioactively contaminated materials.
(i) The Eme'B'nCY Class declared; or section. the bcensee shall notify the (ii) Either paragraph (b)(1). "One. Hour NRC as soon as prac'ical and in all (t.) Followup Notification.With Rrport." or paragraph (b)(2). "Four-Hour cases, within four hours of the respect to the telephone notifications Rzport." as the parsgraph of this section occurrence of any of the following:
made under paragraphs (a) and (b) of requiring notification of the Non-(i) Any event, found while the reactor this section. in addition to making the Emergency Event.
is shutdown, that, had it been found required initial notification, each (b) Non Emergency Events. (1) One.
while the reactor was in operation.
licensee, shall during the course of the Hour Reports.lf not reported as a would have resulted in the nuclear event:
diclaration of an F -rgency Class powerplant, including its principal (1) Immediately report- (i) any further under paragraph (a,
'his section, the safety barriers, beiniseriously degraded degrada' ion in the level of safety of the licensee shall notify a. NRC as soon as or being in an une9alyzed condition that plant or t.'her worsening plant f) y v,7,p nditions, including those that require r co d tio ta sul'ts ur i e ce of e
the declaration of any of the Emergency following:
in manual or automatic actuation of an Classes,if such a declaration has not (i)(A)The initiation of any nuclear Engineered Safety Feature (ESF).
been previously made, or (ii) any change plant shutdown required by the plant's including the Reactor Protection System imm one Emusency Case to anothw. or Tschnical Specifications.
(RPS). However, setuation of an ESF (iii) a termination of the Emergency (B) Any deviation from the plant's including the RPS that results from and Class.
Technical Specifications authorized is part of the preplanned sequence pursuant to i 50.S4(x) of this part.
during testing or reactor operation need (2) Immediately report: (i) the results (ii) Any event or condition during not be reported.
of ensuing evaluations or assessments of cperation that results in the condition of (iii) Any event or condition that alone plant conditions. (ii) the effectiveness of the nuclear powerplant including its could have prevented the fulfillment of response or protective measures taken, principal safety barriers, being seriously the safety function of structures or and (iii)information related to plant degraded; or results in the nuclear systems that are needed to:
behavior that is not understood.
powerplant being:
(A) Shut down the reactor and (3) Maintain an open, continuous (A)In a umanalyzed condition that maintain it in a safe shutdown communication channel with the NRC significantly compromises plant safety; condition.
Operations Center upon request by the (B)In a condition that is outside the (B) Remove residual heat.
NRC.
design basis of the plant; or (C) Control the release of radioactive material, or Deted. at Washington. D.C. this 23d day of
'ouer requiremente for immedow nonkauan of (D) Mitigate the consequences of an August. tes3.
ihe NRC b) bcensed operetas nuclear power accident.
For the Nuclear Regulatory Conun!aion.
resciare m inateined eme nm ie this chepier. ia (iv)(A) Any airborne radioactive I
pernceler. I suas. I so em i so a and I ra.rt' 7elease that exceeds 2 times the Secretoryof the Commiuion.
- N, 7 "" *dd'""d '*
applicable concentrations of the limits scesummtet selephone mueber of the Nec specified in Appendix B. Table 11 of Part fra m ame ru.4 e.smes.:
anme coas ressee opereuone center a tamiest-esso.
20 of this chapter in unrestricted areas.
L-_
g,%8>&@
4.s o
((///
[kg IMAGE EVALUATION 3
,y
+
1'0
'Na E his pm u
u g E
lll 1.1 i "
~
lili gg 1.25 ll 1.4 1.6 j;
4 150mm 6"
- 47 >7//??
/
'b
+>h 4
<4 #w O
t 4
'E ____.
JM.
T
- 9)
((
g[$?g,
% @,3 IMAGE EVALUATION gpf i +9
/4
</,<!jk<
1ss11AaGer<mi-3)
. gy e
- i/
y,,,
+
l.0 Em E yl} Esa l,l l'sEM i.8 I l.25 i
1.4 i.6 1,
-1 4
150mm 4
6"
'4 4
- sIff4/f
?'MM si, t
y
g382 Federal Register / Vcl. 48. No NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 Immedlete Nottfication Am'LTe/4 of Significent Evente At Operating Nuclear Power Reactore Correction In FR Doc. 83-23802 beginning on page 39039 in the issue of Monday. Auguet 29, 1983, make the following corrections to i 50.72 on page 39048:
- 1. In the second line of(a)(1)lasert the words " licensee licensed" between the words " reactor" and "under".
- 2. In the second line of(a)(1)(ll) the word "ths" should read "this".
- 3. In the fourth line of(a)(2) the word "commerical" should read
" commercial".
- 4. In the third and sixth !!nes of (b)(1)(ii) the word "powerplant" should read power plant".
- 5. In the first line of(b')(1)(if)(A) the word "a" should read "an".
- 8. In the fourth line of (b)(1)(ill) the word " power-plant" should read " power plant".
- 7. In the third and sixth lines of (b)(1)(vi) the word "powerplant" shoidd read " power plant". Also in the sixth line of that paragraph the word "nulcear" should read " nuclear".
- 8. In the fifth line of (b)(2)(1) the word "powerplant" should read power plant".
- 9. In the second line of(b)(2 word "an" should read "any" )(ll) the o w wocoesvo u s-=
$RC eonu 335 U.S. NUCLEAR REGUL ATORY COMMIS$10N BIBLIOGRAPHIC DATA SHEET NUREG-1022, S
. No.1
- 4. TITLE AND SUBTITLE (.
M Volume No. of appewreare) 2 (Leave Dianki LICENSEE EVENT RE RT SYSTEM RECIPIENT'S /CES$10N NO Description and Gu elines for Reporting
/
- 7. AL THOR (S) 5 D ATE H[ ORT COMPLE TED MONT[
l y[ AR F. J. Hebdon Fe fuary 1984
- 9. PERFORMING ORGANIZATION NA AND MAILING ADDRFSS (Include Ira Codel D[E REPdHT ISSUED yebruary w"
1984 Office for Analysis & Eva ation of Operational Data U. S. Nuclear Regulatory C ission
[
Washington, DC 20555
/
3,t,,, y,,,,,
- 12. SPONSORING ORGANIZATION NAME AND AILING ADDRESS (/nctuaw 2<p Codel p
" "N" Same as 9. above
[E R800 COVE RE D Iloclutve deras/
- 13. TYPE OF REPOHT Guide
- 15. SUPPLEMENTAHY NOTES 14 (L eave rw n )
16 ABSTR ACT (200 wt"ds or less)
On July 26, 1983, the Commission pu is ed in the Federal Register a final rule (10 CFR 50.73) that modified and codi ed e Licensee Event Report (LER) system.
The rule became effective on January, 198 In September 1983, the NRC published NUREG-1022 which provides supportin informa ;on and guidance that is of interest to persons responsible for the prepar ion and rt iew of LERs. The information contained in NUREG-1022 includes:
(1) a br f descripti of how LERs are analyzed by the NRC, (2) a restatement of the guidanc-contained in e Statement of Consideration that accompanied publication of the IR rule, (3) a s of examples of potentially report-able events with staff ccmment on the actual rep tability of each event, (4) guid-ance on how to prepare an LER including the LER f ms, and (5) guidance on submittal of LERs.
Subsequently, duri the 9eriod from Octo r 25, 1983 to November 16, 1983, the NRC staff held five reg' nal meetings to discuss he scope and content of the LER rule with utility and NRC gional representatives, ing these meetings, numerous questions arose and were swered. This supplement to REG-1022 contains a summary ofthequestionsaskedaftheanswersgiven.
- 17. KE Y WORDS AND DOCUVE N T A LYSIS lla DE SCHsP TOH5 l
17b IDE N ilF IE HS OPE N N DE D TE HYS 18 AV AIL A8ttfi) STAT E VE N T M SE C U N I T Y C L A SS + v ""
21 W. W N si S Unclassified 58 Unlimited 20 SgugTv gg o-
.. mce
% RC F ORM 335 *st a's
UNITE 3 STATES sirs cassezit 2'
NUCLEAR RECULATORY COMMI';SION Postact a e tis esio C
5 '
WASHINGTON, D.C. 20566
,[sl"3 t
..... 1 u a
L OFFICIAL BUSINESS C
PENALTY FOR PRIVATE USE. 4300 P
$1 E.
2 0 !
met
\\
ComZ en 120555019877 1 1ANICV19U11S1 E!
US NRC ADM-DIV CF TIDC m
POLICY & PUB MGT BR-PDR huREG W-501 m2 HASH 1hGTCh CC 20555 j
m B-a Q
k I