ML20087F747

Comment Opposing Rev 1 of NUREG-1022, Event Reporting Sys

ML20087F747
Person / Time
Site:	Catawba
Issue date:	01/15/1992
From:	Tucker H DUKE POWER CO.
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-56FR50598, RTR-NUREG-1022, RULE-PR-50 56FR50598-00005, 56FR50598-5, NUDOCS 9201240124
Download: ML20087F747 (15)

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January 15, 1992 David L. Meyer, Chief Regulatory Publications Ponch Division of Freedom of Information and Public Services Office of Administration U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Duke Power Company LNUREG 1022r Revision 1 Comments Event Reporting Sy:;tems 10 CFR $0.72/73 Gentlemen:

Please find attached our comments to Revision 1 of NUREG 1022, Event Reporting Systems 10 CFR 50.72 and 50.73, Clarification of NRC Systems and Guidelines for Reporting.

A 1990 regulatory impact survey on the effect of NRC regulation on nuclear power plant activities and subsequent event reporting workshops indicated a need for further guidance on the two reporting rules. Experience has shown that the threshold of reporting has not been consistently implemented and some problemr exist with the interpretation of the guidelines and definitions. The proposed revision to NUREG 1022 introduces further confusion into the determination of reportability by drastically changing guidance previously given and used by the industry, which is contrary to the originally desired resulting product from the survey.

The purpose of the reporting guidance should be to assure (potentially) safety significant events are effectively and consistently reported by '.he industry within the regulatory limits defined in the reporting rulemaking prescribed by law. Both the industry and the NRC should take credit for the reduced number of reportable events (Licensee Event Reports, LERs) since 1989, as evidenced by improved performance and reduction of significant accident precursors.

Duke Power is concerned that NUREG 1022, Revision I substantially lowers the threshold of reporting events. The reduced threshold of reporting in many cases is inconsistent with the statements of consideration for 10 CFR 50,72/73 in that events that previously lacked the significance required by the rule would now require reporting. These reporting changes have not been supported by appropriate backDt analyses pursuant to 10 CFR 50.109.

A re'iew of events and problem reports was performed a one of our stations to determine the imph of the draft reporting guidance, and results showed an estimated increase in I hour red phone notifications of 50/yr., an increase in total red phone calls of 70!yr., and an increase 9201240124 920115 PDR NVREQ.

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U. S. Nuclear Regulatory Commission January 15, 1992 Page 2 in LERs of over 80/yr. or 200%.

With a significant increase in the number of 50.72 notifications, along with the increased level of detail now recommended in Section 4.3 of the proposed revision to NUREG 1022, an increase in the arnount of time will be required of niant operators for reporting and away from attending to the plant's event wislent. This is in contradiction to the statement on page 1 of the draft involving operational safety concern versus reporting. The increase in LERs is not only economic, but, that 'he amount of attention necessary for truly safety significant problems may now become diluted by an addition of less significant events to the process. An overall reduction in the quality and level of detail of the process may be the undesired result. Also, a sudden increase in the number of LERs would send an inaccurate message to the public that there could be a major problem in the industry.

Duke Power endorses the positions and those comments submitted by NUh1 ARC and the llWR Owners' Group LER/JCO Committee on this issue.

Please consider our comments and concerns on the proposed revision to NUREG 1022 and direct questions on this subject to David V. Ethington (704) 373 2025.

Very truly yours,

,_4 C~

.WJv / d A / v. g h 7

11. B. Tucker Senior Vice President Nuclear Generation 1022cl/

Attachment cc:

S. D. Ebneter E. L. Jordon Regional Administrator, Region 11 Director, AEOD T. A. Reed, ONRR T. bl. Novak, AEOD R. E. hiartin ONRk W. T. Orders Senior Resident inspector (CNS)

L. A. Wiens, ONRR P. E. Ilarmon P. K. VanDoorn Senior Resident inspector (ONS)

Senior Resident inspector (h1NS)

W. J. IIall, NUh1 ARC

NUREG 1022, REVISION 1 COhlh1ENTS 10 CFR 50.72/73 REPORTING CRITERIA SECTION 2: REPOllTING AREAS WAltRANTING SPECIAL h1ENT10N NUREG: [pl6,s2.4,Ist p]

Repor' ability judgments for each potentially reportable item of such reviews should be made in a timeframe that is commensurate with the possible safety significance of the item.

COhlh!FNT:

"Reportability judgments..." should be changed to "Operabillly judgments...". Reporting is based on the results of the operability determination when performing design reviews.

NUREG: [p16,s2.4,3rd pl The discovery date for deficiencies identified in a design review is the time when it is determined that a condition exists 1%t is reportable.

COhlhtFNI:

The " discovery date" for deficiencie:Npitified in a design review should not begin until station management is aware of the coriditionNr.d ccacurs with the operability determination. Afost engineering groups perft rmh g reyi;we of this type are not located on site and are not considered the " Licensee". Only the Ughe'e can make the required reportability determination.

NUREGt (pl8,s2.7,3rd p]

The proper interpretation is to assume that such multiple failures or inoperabilities concurrently existed (particuiarly because of the short interval between each test) and are therefore reportable.

COMh1ENT:

This-interpretation is in direct conflict with the philosophy of considering a component inoperable at time of discovery during a surveillance, unless firm evidence exists to the contrary (See NRC statement p35).

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.4, Page 2 NUREG 1022, REYlSION I COMMENTS SECTION 3: SPECIFIC REPORTING GUIDELINES 3.2.2 - Condition Prohibited by Tech Specs NUREG: [p35,s3.2.2(3))

if the surveillance interval plus the allowable time extensions for conducting a surveillance are exceeded, the event is reportable even though the surveillance is subsequently satisfactorily i

performed.

COMMENT:

For a missed surveillance, the event should not be reported unless the surveillance interval +

allowable time extension (25%) + LCO Action for the inoperable system is execeded. Per Tech Spec 4_0.3, surveillances do not have to be performed on inoperable trains / systems. Once l

surveillance interval + ext, is exceeded, system / train is inoperable per TS 4.0.3, but not yet reportable because the plant is not in a " condition prohibited by Tech Specs" (i.e. the LCO Action is being met).

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' NUREG: [p36,s3.2.2(5) & p38,s3.M Ex.4J Administrative Requirements Required by Section 6 of the STS - If a requirement is only administrative and does not affect plant operation, then an LER is not required.

. COMMENT: -

Like Section 6, there are some administrative requirements located in Sections 3 & 4 of the STS that, if violated, would not affect the operation of the plant and should, therefore, be addressed

-in this paragraph also (e.g. Time requirements for submission of Tech Spec Special Reports).

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NUREG: [p36,s3.2.2(6)]

Entry into TS 3.0.3 for any reason orjustification is reportable.

COMMENT:'

May want to note that many TS 3.0.3 entries are as a result of 2 trains rendered inoperable from a single cause and that 50.72b2(iii) consideration should be given.

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Page 3 NUltEG 1022 REVISION 1 COMMENTS NUREG: [p36,s3.2.2(7)]

If an IST or ISI is not performed when required, or if ASME Section XI tests or inspections show that components fall to meet requirements, the failures are re;mrtable when they cause the associated systems required for safety to be declared inoperable.

COMMENT:

Agree that component not meeting Sect XI should be evaluated for operability befort being declared inoperable. If determined inoperable, then reportability needs to be considered.

Disagree that component failure is reportable once determined inoperable. This should be treated like any other surveillance (i.e. inoperable at time of discovery unless firm evidence to the contrary. See NitC statement, p35).

NUltEG: {p39,s3.2.2 Ex 5]

(i.e. ASME BPV section IX,)

COMMENT:

Section IX should be section XI. Also, same comment as p36, section 3.2.2(7).

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Page 4 I

NUREG 1022, REVISION 1 COMMENTS I

3.2.4 - Operating Plant in Seriously Degraded or Unanalyzed Condition or Outside Design Hasts

GENERAL COMMENT

(pgdt thru 45,s3.2.4, esp (1) & (3)J The threshold for reporting smdct this section is far too low. The dennitions of " engineering i

- design bases" and " licensing basis" are taken from NUREG 1397, which discusses the operability and design of specific components, trains, and systems, and applied to this section out of context. As written, these paragraphs state that a single inoperable component, system, or structure places the plant outside its design basis. This is clearly not in accordance with the original rule. The " design basis of the plant" means that set of analyzed transients and accidents including assumed consequential and independent failures, contained in the latest docketed Safety Analysis Report. Acceptability of these analyses is reDected in performance of a plants' principle safety barriers. The bounds of a plants' design basis are reDected in its Technical Specification (i.e. Safety Limits). This position is further supported by_ Generic Letter 91-18, Technical Guidance " Operable / Operability: Ensuring the Functional Capability of a System or Component".

2 Therefore, to be outside the design basis of the plant, you must be octside the analyzed envelope either by having multiple systems inoperable or discovering errors in analyzed conditions which result in signincant changes to the acceptance criteria for a plants principle safety barrier (s).

As written, this section s'ates that some loss of quality or functional capability in a single plant component places the plant in a seriously degraded condition. This, too, is not in accordance with the original rule. As noted in. the statements of consideration for the original ru!c, paragraph 50.72bl(ii).is not intended to apply "to problems concerning single pieces of equipment."

t SPECIFIC COMMFNI'S:

NUREG: [p45,s3.2.4(4)]

The plant is operating outside existing required opcrating or emergency procedures for safet)-

related equipment [ minor valve mirelignments, such as local instrument root valve, are not reportable. Significant valve misalignments are reportable.)__

- COMMENT:

This bulletiis not clear. For valve misalignments resulting in operation outside required procedures, it is not clear whether the procedures are non existent for the resulting plant

- conditions, or the procedures exist but were.not complied with Also, "significant valve misalignments" is too vague and needs further clari0 cation (i.e. significant valve misalignments could render safety system inoperable).

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1 Page5 NUREG 1022, REVISION 1 COMMENTS NUREG: [p46,s3.2.4 Ex.1)

Plant Being Seriously Degraded, Reportable Events:

- physical deformation to SSC that could reasonable have resulted from waterhammer...

- an inadvertent loss of a significant quantity (> 100 gal) of the reactor coolant system inv;ntory..

- a reactor trip breaker failing its trip bar lift force measurement test..

COMMENT:

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The above examples are weak in that they would not necessarily put the plant in a seriously i

degraded condition.

NUREG: [p46,s3.2.4 Ex.1]

Daring surveillance test of the containment door interlock, the inner door failed open...

COMMENT:

No mention of condition of outer door. Tech Specs conta'm provisions and allowances for 1 inoperable door. Normally, tests of this type would require outer door to be closed.

NUREG: [p47,s3,2.4 Ex.1]

Degraded Reactor _IIcad Stud: testing of a reactor head stud revealed the stud hardness was outside the FSAR requirements by 8 hardness numbers.

COMMENT: -

This example is reportable only if Engineering determines studs will still not meet acceptable

- design stresses.

NUREG: [p47,s3.2.4 Ex 2) Plant in Unanalyzed Condition Spilla Gat creart conditionn that could affect component operability, qualification, or design

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Single component or system failure would not necessarily put

• plant" as a whole in unana!yred ~

condition (see general comments for this section).

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Page 6 NUREG 1022. REVISION 1 COMMENTS NUREG: [p47,s3.2.4 Ex.2]

Serious RCS umperature or pressure transients exceeding design or "Icch Spec limits are reportable.

COMMENT:

RCS pressure / temperature transients e uong TS LCO limits are often evaluated to be acceptable (e.g. PZR exceeded co4Marr, temperature rate in Tech Specs over a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> perhid).

Tech Specs contain provisions and ticWns b such transients. This should not be reported as "an

- unanalynd condition of the plant da.t alghlficantly compromises plant safety", if the RCS (or PZR) is determined operable by HQW.eting.

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- NUREG:' [p49,s3.2.4 Ex.3]

Service Water system leaks: Inhge is mportable if the licensec is not in compliance with Generic 1.ctter 90-05, the code eder which the piping was designed, or the action statement in the LCO for op:rability of the system.

' COMMENT:

If Service Water system is evaluated and determined to be able to perform its intended function (i.e. pass acceptable flow and provide adequate cooling) and therefore operable, despite noncompliance with a code or Generic Letter, the condition should not be reported under this 4

section.

- NUREGt [p49/50,3.2.4 Ex.3]

Reportable Events Examples COMMENT:

See general comments under this section. Many of these examples are not appropriate examples for reporting under outside the plants' design basis. Many of the examples used are a degraded l

condition where full qualificatlan is not confirmed for specific components or systems (i.e. a 1

- code or standard is not fully. met).-Unless these degraded conditions affect safety system-operability. and places the plant outside the analyzed envelope, the coMitirent sho*l not be reported per this criterion.

GENERAL COMMENT

for Examples in this Section:

All examples provided descriSe conditions determined to be reportable. To be more useful, the examples should also indicate what change in the condition would make it not reportable. Such a description would allow users of the guidance to understand the distinction that makes one condition reportable and another not reportable.

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Page 7 NUREG 1022, REYlSION 1 COMMlWTS i

l 3.2.5/3.2.8. Esternal/ Internal' threat to Plant Safety i

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GENERAL COMMENT

[pss 52 55;64 69,s3.2.5/3.2.8)

It should be clarliled in these sections that situations that do not 'actually threaten" the safety l

of the plant or 'significantly hamper site personnel in the performance of their dutles" do not need to be reported even though station management decides to take a conservative precautionary

. measure such as holding additional personnel over their scheduled time off. Conservative t

. precautionary compensatory measures should not be misconstrued as plant safety being threatened (and reported), but good management practices implemented, t

i SPEC 1MC COMMFNTS:

NUREG: [p72 3.2.8 Ex.1) Toxic Gas Release 4

The plant's control room ventilation isolated when the toxie gas initiated on a valid signal it is

- also reportable because of the ESP actuation.

COMMENT:

j Agree event is reportable as an internal threat to the plant, but should not require reporting as an ESF Actuation. holation of the Control Room Ventilation system via a toxic gas signal (i.e.

l chlorine monitor) is not an Engineered Safety Feature.

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r Page 8 NUREG 1022, REVISION 1 COMMENTS 3.3.1. Shutdowa Plant Found in Degraded or Unanalyzed Condition

GENERAL COMMENT

S: [p76 79,s3.3.1]

See General Comments under scetion 3.2.4 involving component / system specine inopera e s

functions as they relate to the entire plant

• safety functions.

Also, many of this sections _' examples assume that conditions that are discovered after a failed j

surveillance might have existed during plant operation and are therefore reportable under this section. This philosophy is not in accordance with previous guidance on this criterion and others.

The discovery of a condition while shutdown during tests or surveillance, that results in the

.,i inoperability of systems,-is assumed to be inoperable at the time of discovery unless firm evidence exists to the contrary (See NRC statement, p35).

SPECIFIC COMMENTS:

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NUREG: [p77,3.3.1 Ex.3]

The ability of the control room emergency ventilation systerr. to perform its design cooling function could not be confirmed under the current analytical assumptionst therefore, the plant was considered to be in an unanalyzed condition.

t COMMENT:

Condition is reportable as a loss of safety system functio 1(50.72b2(iii))t however, the condition

. does not necessarily put the plant in an unanalyzed condition that compromises plant safety. Not eNugh information is given with respect to the higher temperatures effect on safety systems necessary to mitigate the consequences of an accident previously analyzed.in the FSAR. The l'

inoperability of the C9atrol Room Ventilation system does not, in itself, constitute the "nlant being in an unanalyzed condition that significantly compromises plant safety.

-q NUREG: [p78 s3.3.1 Ex)]-

Required containment integrity. was lost (Hot Shutdown) as a result of a pack.ing leak on a containment personnel airlock door _ lock; operator equalizing valve. An ENS notification is u

required because the loss of containment integrity, had it existed while the reactor was in operation, would have resulted in a serious degradation of a primary $afety barrier, i

COMMENT:--

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. ' Assuming the other airlock door was operable, this can not be considered a loss of containment

-integrity not a seriously degraded barrier. Tech Specs provide allowances when 1 out of 2 airlock doors are inoperable. This example also assumes the packing leaks existed during plant

. opetation (see general comments this section).

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Page 9 NUREG 1022, REVISION 1 COMMENTS l

NUREG: [p78,53.3.1 Ex,6J A IlP1 exhaust check valve failed its local leak rate test, putting the combined LLRT for all valves and penetrations above their TS limit of 0.612. An ENS notification is required because the failure to meet the TS LLRT limit, had it been found while the reactor was in operation, would be a serious degradation of a principle safety barrier.

COMMENT:

One doesn't know if this valve or any of the other valves' condition existed during operation.

Sec general comments this section Also, exeecding the TS limit of 0.6 La does not necessarily mean there is a serious degradation of a principle safety barrier (e.g. The plant is still considered to be within its design basis if containment leakage is < La).

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o Page 10 NUREG 1022, REVISION 1 COMMENTS 3.3.2 Actuation of an Engineered Safety Feature or Reactor Protection System i

GENERAL COMMENT

S: [p80 84,s3.3.2]

l ESF systems vary from station to station based on the needs to mitigate the consequences of an accident. For most plants, FSAR Chapter 6 identifies those systems, There may alt,o be support systems to each ESF system whhp are not identified in this chapter. These supporting systems i

were not considered as ESF sy tems but referred to as essential auxiliary supporting (EAS) systems Chapter 15 of the PSAR may include discussions of additional systems that are not considered ESP systems but only mentioned as an alternate means to mitigate the consequences of an accident.

The Standard Review Plan (Sect.7.3) distinguishes the differences between typical Engineered Safety Systems and Essential Auxiliary Supporting Systems. Many examples provided in this section appear to be a change in how ESF systems aru defined rather than clarifying reporting requirements of ESF Actuations. Redefining Licensee's current definition of USP systems

. through this NUREO (instead of a Rule change) will undoubtedly lead to further confusion to -

plant personnel, j

i NUREG: [p82,s3.3.2]

Table 2, Typical ESP Systems -

COMMENT:

J This table serves no useful purpose to the user of this guidance and will probably result in more confusion since ESP systems are plant specific.

NUREG: [p84,s3.3.2]

f The guidance given for RPS and ESF definitions, reportability, and exceptions, also applies to the reporting of ATWS system actuations er failures to actuate.

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COMMENT:

Although the ATWS system is a backup for kPS, the system should not be considered as part of the reactor protection system, and therefore, should not be required to be reported.

NUREG: [p87 s3.3.2 Ex.7J l

l A; voltage transient caused spiking of a rad monitor resulting in isolation of the Control Room-Ventilation system, and is therefore reportable, i

COMMENTr lsolation of the CRV via a rad monitor is not an ESF function.

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Page 11 NUREG 1022, REVISION 1 COMMENTS 3.3.3. Event or Condition that Alone could have Prevented Fulfillment of the Snfety Function of Systems NUREG: [p91,s3.3.3,2nd p)

If either offsite power or onsite emergency power is unavrilable to the plant, it is reportatile.

COMMENT:

Loss of offsite power should not be reported under this section since it is not considered to be a plant system performing safety functions and taken credit for in the accident analysis.

However, a loss of offsite power and consequences thereof, may be reportable under other criterion (e.g. Unusual Event).

NUREG: [p92,s3.3.3) Multiple Independent Failures Whenever there are a number of simultaneous independent events or conditions that cause 2 or more functionally redundant trains to be unable to perform their safety functions concurrently, they are reportable.

COMMENT:

This bullet is clearly in conflict with the Rule and statements of consideration. The rule requires "the event or condition that alone could have...". Multiple independent failures of I systems' trains may, however, be required to be reported as a condition prohibited by Tech Specs.

NUREG: [p95/96,s3.3.3 Ex 5)

The event is reportable under this criterion and 50.73a2(vil)(common mode failure) because both trains of emergency power and service water were simultimeously inoperable by different causes at different times.

COMMENT:

Same comment as p92. A system wheic 2 trains are rendered inoperable by different causes during the same time frame should not be reporal under this criterion. 50.73a2(i)(11), Condition Prohibited by Tech Specs would apply in this case. Also, this event would not be reportable under 50.73a2(vii) for the same reason.

NUREG: [p96,3.3.3 Ex.6].

During Refueling,1 D/O was out of service for maintenance and the second D/G was declared inoperable. An ENS notification and LER is required under this criterion.

COMMENT:

See comment p92/95. If the D/G TS LCO Action was complied with, the event is not reportable.

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page 12 NUREG 1022, REVISION 1 COhth1ENTS SECTION 3.3.7 News Release or Other Government Notifications GENERAL COh!MENTS: [p14114,s3.3.7J The draft NUREG presents more information under this very subjective criterion than currently exists; howt:yer, the reporting of non-radiological environmental incidents still needs further clarineation or discussion. On occasion, after a minor incident affecting the environment, the station will notify certain Eovernment agencies as a cour:esy, but not rcquired. A question of when the NRC should be notified from these type of ' vents still remains, it is difneult to determine, in some cases When an event may or may not be pereelved by the public as "significant", and therefore reportable.

Guldance under this scetion could be strengthened by additional discussion for the above events, as well as, several more examples of incidents that require and do not require red phone notifleations.

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Fast 13 NIJREG 1022, REVISION 1 COMMENTS SECTION 41 EMERGENCY NOTIFICATION SYSTEM REPORTING 4.3 - T pleal ENS Reporting issues 3

GENERAL COMMFNI'S 1pl35152,s4.3.1 & 2]

It should te over emphasired in this section that the first,sriority of the SRO on duty is to maintain the plant in a safe condition. Many transients /eveats that occur require the operators' full attention more than just the first critical "few minutes". This section also includes several questions under the reporting criteria that would appear to take even more time from the SRO in the performance of his duties, than normally requested during a red phone notification. For many of the questions, the SRO typically does not have that information availab!c during the initial call. Therefore, it should be made clear in this document that the usual information

- requested by the NRC as listed in this section, should _only be tised as informal 1,uldance to the communicator in preparing the report and that the IIcadquarters Operation Ofncer should keep the SRO's first priority in mind by not keeping him on the line any longer than necessary during the course of an event.

SPECIFIC COMMENTS:

NUREG [p129,2nd p]

Reporting of design problems should be made on the basis of engineering judgment, instead of engineering reviews taking many months, if the licensee initially decides that a problem is

- signidcant er.ough to enter a TS LCO or take other ecmpensatory :,casures, it is immediately reportable on that evidence alone.

COMMENT:

If an LCO Action statement is entered, then the licensee has made a decision (by whatever basis) to declare the SSC inoperable and a reportability determination can be made at that time.

However, the licensee may take very conservative compensatory measures when the outcome of the at alysis is unknown, but the consequences could be significant. These are good, safe

- management practices and should not be discouraged by requiring an unknown condition to be i

reported, NUREG: (pl40,s4.3.2, top bullet]

..whether a JCO is necessary or being prepared COMMENT:

- JCO should be changed to Waiver of Compliance (WOC), if a JCO is ' acing prepared, then a WOC is going to be requested, by definition, since the JCO is the written technical basis for the Waiver. It should be noted, however, that the ENS phone call is not the appropriate " arena" to initiate discussions concerning Walvers of Compliance.

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