ML20091F950

Submits Comments Opposing Draft NUREG-1022, Event Reporting Sys,10CFR50.72 & 50.73. Licensee Feels That Changes to Intial NUREG-1022 Increases Util Expenses W/O Improving Public Health & Safety

ML20091F950
Person / Time
Site:	Callaway
Issue date:	12/02/1991
From:	Passwater A UNION ELECTRIC CO.
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-56FR50598, RTR-NUREG-1022, RULE-PR-50 56FR50598-00002, 56FR50598-2, ULNRC-2522, NUDOCS 9112100086
Download: ML20091F950 (46)

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C#aww PLvit December 2, 199i h-MM Q

sS 55 U.S. Nuclear Regulatory Commission

'pyg Attn:

Mr. David L. Meyer c3 sn Chief, Regulatory Publications Branch O

Ji Division of Freedom of Information "4

and Publication Services Office of Administration Washington, D.C.

2055:1 ULNRC-2522

Dear Mr. Meyer:

DOCKET NUMBER 50-483 CALLAWAY PIANT COMMENTS ON DRAFT NUREG-1022,

" EVENT REPORTING SYSTEMS. 10CFR50,72 AND 50,73" Union Electric Company submits the attache'd comments - to the subject draf t NUREC-1022 The comments are marked on the attached applicable pages of the -

draf t NUREG, A summary of the comments is also provided on a-separate attachment,

-Sincerely, de A. C. Passwater-Manager,=-

, Licensing &-Fuels JDB/TPS/1rj Attachments cc:- -distribution attached 9112100086'911202

PDR PR

2 56FR50598.

PDR r,-

Maiwy wess P.O. Box 620, Fulton MO 65251 J

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ec distribution for ULNRC-2522 T. A. Faxter, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 North Street, N.W.

Washington, D.C.

20037 Dr. J. O. Cermak CFA. Inc, 18225 A Flower Hill Way Caithersburg, MD 20879-5334 R. C. Rnop Chief, Reactor Project brench 1 U.S. Nuclear Regulatory Commission Region III 79a Roosevelt Road Clen Ellyn, Illinois 60137 Bruce Bartlett Callaway Resident Office U.S. Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 J. R. Hall (2 copies).

U.S. Nuclear Regulatory Commission l

OWFN - Mail Stop-13E21 Washington, D.C.

20555 l

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. Manager, - Electric Department Missouri Public Service Commission P. O. Box 360 Jefferson City, MO 65102 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station P1-137 Washington, D.C.

'20555-Merlin Williams Wolf Creek Nuclear Operating Corporation P. O. Box 411 Burlington, KS 66839:

Jim Eaton Nuclear Management 6 Resources Council 1776 Eye Street, NW Suite 1300 Washington, D.C.

20006-2496

t UNION ELECTRIC, CALLAVAY PLANT ATTACHMENT TO ULNRC-2522

SUMMARY

OF DRAFT NUREG-1022 COMMENTS Overall Comments:

A number of the proposed rule interpretations contrast sharply with the original NUREG 1022 and its two supplements. These deletions /additiona to the previous guidance appear to be intended solely to lower the reporting threshold in some areas, thereby increasing utility expenses without improving public health and safety. If the reporting threshold is da be lowered, it should be done with a rule change rather than by intripretation guidance. See the following specific comments for examp'.es.

As a whole, the proposed NUREG 1022 revision confirms seme of our previous interpretations, but does not provide a net relief from reporting items of a_ low threshold. If the comments-are incorporated,-the final NUREG 1022 revision will be much more beneficial.

Specific Comments:

2.7, page 18 Disagree that a single component failure discovered during surveillance testing is reportable if the failure mechanism could reasonably be expected to occur-in one or.

more. redundant components and thereby prevent fulfillment-of the system's safety' function. Merely predicting failure is not firm evidence that the redundant compo,ents could have failed. Surveillance testing of the redu. 3 ant components would uncover the failure mechanism 2.7, page 18 The last two paragraphs are not consistent with Sections 5.2.1 and 3.2.2, pages 35 and 37,..

concerning the " time of discovery". If there -is firm evidence the common failure condition existed prior to the surveillance testing, then the condition should be reported. Reference the previous NRC guidance per NUREG 1022 Supplement 1, answer 2.3.

3.2.1,.page 31 The definition of initiation of any nuclearL plant shutdown.is not-clear for a T/S required shutdown begun in Modes 3'or 4 with completion in Modes 4 or 5. The temperature / pressure reductions of these modes occur after the plant is suberitical, 1

Page 1uof 4

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3.2.2(5),

The new guidance is not as clear as previously page 36 provided by NUREG 1022 Supplement 1, answer 2.9. This is especially true for inadequate liealth Physics posting conditions.

3.2.2(6),

A Temporary Waiver of Compliance (TWOC) is page 36 usually requested and certainly not approved by the NRC Staff until after STS 3.0.3 has been entered. Therefore, a 50.72 notification will probably be made because it is doubtful the TWOC will be approved within 60 minutes, llowever, an LER will not be sent if the TWOC is approved.

(1), page 37 The proposed wording will confuse the operators.

Use LCO and action statement terminology consistent with Generic Letter 87-09, 3.2.4(2),

The draft guidance has added "potentially" page 43 or "potentially could" in the definition for unanalyzed condition. This change-is contrary to the previous guidance provided by NUREG 1022 Supplement 1, answers 4.1 and 10.3. It is also contrary to the rule which discusses if a condition results in the plant being in an unanalyzed condition.

The rule does not use "potentially" or "could have" but uses present or past tense for the existing condition.

3.2.4(4),

Reporting significant valve misalignments'as a-plant page 45 condition not covered by operating'and emergency procedures is confusing. If valves in.a safety-related or: support system are misaligned, an operability evaluation by the opera ors or engineers will be performed. In most cases; an NRC notification will be made because the: valve condition rendered-one or more trains of the system inoperable not.because procedures are inadequate. Delete.this example.

3.2.4(3),

The untested-containment isolation valves should page 48

- be treated' as a missed - surveillance, especially:

if-subsec;2ent testing meets the-acceptance criteria.

Loss of containment integrity per STS-3.6.1.1 should.

not be ' assumed in this case. STS _3.6.1. 2. and 3.6. 3 -

actions should be followed. Delete the example from this section.

3.2.6(2),

Planned outages of the plant computer areanotj page 61-addressed.

3.2.8, page 64 Discharges of halon systems to unoccupied rooms and rooms which will not require operator access 'for plant operation should not be reported.

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Pagel2 of 4

3.2.8, page 65 Merely using radiation work permits or protective clothing is too low a reporting threshold for "significantly hampering site personnel."

3.2.8, page 69 55 gallons should not be inferred as the limit for reporting significant spills.

3.3.2(1), pg.816 Since plants rarely have the same design, each plant 3.3.2(6), pg.87 should define their ESF systems in Chapter 6 of the FSAR per Regulatory Guide 1.70. Previous NUREG 1022 Supplement 1 answers 6.1 and 6,2 state so. The proposed guidance will increase confusion. This is another case where the NRC staff is appearing to lower the reporting threshold without changing the rule and without enhancing public health and safety.

3.3.2(3),

The threshold for ESF actuation reporting needs to page 83 include a requirement for the electrical /electrcnic signal to travel through the ESF logic system. The proposed guidance will create a low reporting threshold with increased nuisance _ reporting.

3.3.2(2),

It is not clear how an invalid signal may occur to page 84 actuate-an ESF system if the system has been properly removed from service. Delete this example, 3.3.2(1),

If the RPS is properly removed from service-such that page 85 a signal to open the reactor trip breakers cannot be sent, then an invalid signal processed by_the RPS should not be reported. Per plant procedures, it is planned and known the reactor trip breakers are removed from service.-This was discussed in March 1986 with Mr.

Fred Hebdon (AEOD).

3.3.3(3),

The guidance is_not consistent with previous guidance page 94 provided by NUREG 1022 Supplement 1, answer 7.13.

If a system is not in STS and is not. required >to' meet the single failure criterion' it does not perform a-

" safety function." Additionally,;the:second-to last

- paragraph of page_90 infers the safety function applies during the operation of a system (safety or non-safety related) as described or relied-on in the plar.afety analysis. If.a non-safety system's operation

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is not required by the plant safety l analysis, this condition is not reportable. It appears this change was made for the sole purpose of increasing reporting requirements without-changing the rule.

3.3.7,-

Verbatim compliance with the rule requires:the licensee pages 109 & 114 to call the NRC when other government agencies:

are notified,-especially.if the_latter are required by law.

This appears to be an-interpretation of convenience when-in reality the rule should be changed.

-Page 3 of 4-

i t.

Editorial-Comments:

page vi Add:

30-Day 2.5, page 17 Add: voluntary 2.8, page 19 Move to 5.2, pages 166 and 167 to combine with same subject matter to facilitate finding it.

2.9, page 19 Move to 5.1.5 to combine in order to find-it

'in one place.

(4), page 38 Replace:

"or had a high potential for" with.

10CFR20.403 wording:

"may have caused or threatens to cause."

(1), page 47 Replace:

"FSAR" with=" design".

3.2.8, page 64 Add:

"Which may pose a threat" to middle af page.

Page 4 of.4

CONTENTS Page NOTICE.

11 ABSTRACT iii EXECUTIVE

SUMMARY

xi ACKNOWLEDGMENTS.

xiii ABBREVIATIONS xv 1

INTRODUCTION.

1

1.1 Background

1 1.2 Reporting Guidelines and Industry Experience 2

1.3 Revised Reporting Guidelines 3

1.4 How to Use This Document 6

2 REPORTING AREAS WARRANTING SPECIAL MENTION.

13 2.1 Engineering Judgment 13 2.2 Differences in Tense Between 10 CFR 50.72 and 50.73 15 2.3 Reporting Multiple Failures and Related Events 15 2.4 Deficiencies Discovered During Design-Bases Documentation Reviews, Safety System Functional Inspections, and Other Licensee Engineering r

Reviews.

15 2.5 10 CFR 50.9 Reporting.

17 2.6 Events and Conditions Initially Communicated Verbally to NRC Staff or Identified by NRC Inspections.

17 2.7 Multiple Component Failures During Surveillance Testing.

17 2.8 Human Performance Issues 19 2.9 Voluntary Reporting.

19 2.10 Retraction / Cancellation of Event Reports 20 3

SPECIFIC REPORTING GUILELINES 21 3.1 10 CFR 50.72 and 50.73 General Requirements 22 3.1.1 10 CFR 50.72 Immediate Notificaticn Requirements for Operating Nuclear Reactors S50.72(a) 22 3.1.2 10 CFR 50.73 Licensee Event Report Syctam S50.73 (a) (1) 29 v

Oraft NU2ZC-10:2, Rav. 1

3.2 1-Hour ENS Notifications and 30-Day LER Reports.

30 3.2.1 Plant Shutdown Required by Technical Specifications 550. 72 (b) (1) (1) (A) and 550.73 (a) (2) (1) ( A) 31 3.2.2 Technical Specification Prohibited Operation or Condition 550. 73 (a) (2) (1) (B) 34 3.2.3 Technical Specification Deviation per 550.54(x) 550. 72 (b) (1) (i) (B) and 550. 73 (a) (2) (1) (C) 40 3.2.4 Operating Plant in a Degraded or Unanalyzed Condition 550.72 (b) (1) (ii) and

$50.73 (a) (2) (ii) 41 Plant Being Seriously Degraded 43 Plant in an Unanalyzed condition 43 Plant in Condition outside Design Basis.

44 Plant Condition Not Covered by Operating and Emergency Procec..as 45 3.2.5 Natural Phenomenon or Condition Threatening Plant Safety (External Threat)

S50.72 (b) (1) (iii) and 550.73 (a) (2) (iii) 52 3.2.6 ECCS Discharge into the Reactor Coolant System 550. 72 (b)-(1) (iv) 56 l

3.2.7 Loss of Emergency-Assessment, Response, or Communications 550. 72 (b) (1) (v)

............. - 59 Loss of Emergency _ Assessment Capability _.

59 Loss of Offsite Response Capability.

60 Loss of Communications capability..

61 3.2.8 Internal Threat to. Plant Safety

$50. 72 (b) (1) (vi) and 550.73 (a) (2) (x) 64-L Fire Threat.

67.

Toxic. Gas Threat 68

' Radioactive Release. Threat ~~g_}.

68 In-Plant Spill / Flood / Threat 69

/ l30 T>o

? cur-Hour ENS Notifications ghdALER R pet)ts.

3.3 75 vs 3.3.1 Shutdevn Plant Found in-Oegr2ded er Unanalyzed Condition L

-530.7-(b)j;)(1) 73-Oraf; NUREG-1022, Re v.-

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criteria noted above.

The ENS notification is to include what is known at that time.

The following LER may include similar overloaded hangers that are found during the 30-day period.

2.5 10 CFR 50.9 Reecrtine The stated intent for 10 CFR 50.9(a) is that infor=ation provided to the Commission by a licensee be complete and accurate in all material respects.

Sections 50.72 and 50.73 have provisions for updating and revising reports that should be used to correct material incompleteness or inaccuracies that are discovered.

For example, submittal of a revised LER is appropriate to correct any previously submitted inaccuracies of a material nature.

The stated intent for 10 CFR 50.9(b) is that any licensee information with significant health, safety, common defense, or security implications is to be reported to the NRC notwithstanding the absence of a specific reporting requirement.

The Statements of Consideration for 10 CFR 50.9 refer to such licensee,information as'" residual information" that could affect licensed activities.

Licensees may report such information under the6LER format to give the information broad consideration, as di'scuss,ed in Section 5.1.5 'of this report.

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TNesprovisions of 10 cm ;S0.9 should not be used to report information that is> required to be reported under 10 CFR 50.72 or 50.73.

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2.6 Events and Conditions Initially Communicated Verbally to NRC i

Staff or Identified by NRC Insooctions some licensees erroneously believed that if a reportable event or condition had been discussed with the resident inspector or other NRC staff, there was no need to report under 10 CFR 50.72 and

'50.73 because the NRC was aware of the' situation.

Some licensees also expressed a similar understanding for cases in which the NRC l

staff identified a reportable event or condition to the licensee via inspection or assessment activities.

Such means do not satisfy the event reporting rules.

The requirement is to report to the ENS and LER systems events or conditions meeting the criteria stated in the rules so.that the events or conditions can receive structured NRC reviews set up for that purpose and they can be collected, stored and retrieved as operating experience information.

Licensees n,ot submitting infer =stien in accordance with the reporting rules are subject to enforce =ent action.

0.7 Multicle Conronent Tsilur3s Ourine Surveillance Tesiing There have been runercu' cases ir which licencesc S.P.ve n:t reported multiple, sequentially discovered failures of systems or comp nents ;;;urring during planned testing.

This si uaticn was identified as.a generic concern on April 13, 1985, in NRC n

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Infor=ation Notice (IN) 85-27 (" Notifications to the NRC Operations Center and Reporting Events in Licensee Event Reports") regarding the reportability of multiple events in accordance with SS50.72 (b) (2) (iii), 50.73 (a) (2) (1) (B),

50. 7 3 (a) (2) (v), and 50.73 (a) (2) (vii).

IN 85-27 described cultiple failures of a reactor protection system during control rod insertion testing of a reactor at power.

One of the control rods stuck.

Subsequent testing identified 3 additional rods that would not insert (scram) into the core and 11 control rods that had an initial hesitation before insertion.

The licensee considered each failure as a single random failure; thus each was determined not to be reportable.

Subsequent assessments indicated that the instrument air system, which was to be oil-free, was contaminated with oil that was causing the scram solenoid valves to fail.

While the failure of a single rod to insert may not cause a reasonable doubt that other rods would fail-to insert, the failure of more than one rod does cause a reasonable doubt that other rods could-be af f ected _tfhus_af f ecting_thpaf ety-function of-the7opar-g e.sm %t A single component failure in a safety sys. tam is reportable if it h) w;m9p is-determined that the failure mechanism could reasonably be 2.23.

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e_xpected_to cecur in one or more redundant components and thereby/

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Some licensees have misinterpreted the reporting requirements and sa.%

considered multiple failures of similar components (in which each we.

gkeAcomponent was inoperable during the required surveillance testing) as a series of. individual events.

They improperly f((]4'multiplefailuresorinoperabilitiesconcurrentlyex d% reasoned that each individual-component failure, in itself, was ot reportable.

The proper interpretation is to assume that such g

(p,articularlyJesAusAoLt hort interval between each test),

a fore reportable.

Another example of an improper determination of reportability involved'the sequential testing of main steam safety valves.

Of the 20-safety relief valves tested, 17 were out of. tolerance-(13 with set points above the technical specification limit and 4 below the limit). -Individuel valves were out of specification by as much as 4-percent.

The_ licensee initially did-not report this condition because it believed the valves could' fulfill their safety function because no-safety relief valve set pressure exceeded 1397 psia (110 percent of the system design pressure).

However, the licensee determined a commop-codeLAiluteJeghamir was tne cause for most of tne faa. lures;/therefore, une-condition gpamma G7w

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'2.8 Human Performance Inngg

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Human performance often, beneficially or detrimentally, I

influences the outcome of nuclear power plant events.

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Detrimental personnel erro;s may be caused by inadequate N

procedures, training, verbal communications, human engineering, s

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quality control management, or supervision.

A specific description of the causes and effects of human N

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performance as they relate to an event are to be included in the

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LER pursuant to 550.73 (b) (2).

Based on recent NRC site visits to better understand operator response to plant events, it was found x

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that significant human performance information was known to the

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licensees; however, the licensees had not generally included the information in the submitted LERs.

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While complete human i

performance information may not be available at the time of an ENS notification, the NRC is interested in any known human

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performance issues related to the event.

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In the LER, and where possible in the ENS notification, the intent is to include a substantive description of relevant human

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performance information and root causes.

Typical examples of

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human performance pre lens as they relate to the event or root

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cause are given in "

tion 5.2.1(2) of this report.

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,'2.9 ' Voluntary Jing g

g The Statementt Consideration for 10 CFR 50.73 specifically l%M l

address the ufa of voluntary LERs.

Licensees are permitted and

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encouraged to report any event or condition that does not meet the criteria contained in 550.73(a) if the licensee believes that

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the event or condition might be of safety significance or of

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generic interest or ev.cern.

Thus, regardless of operational

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mode, if a fallure or degradation of a component, system, or structure could have generic safety implications or be a precursor to a significant event and no part of 10 CFR 50.73 j

specifically requires reporting, it is intended that the event be

,7 reported as a voluntary LER.

, Voluntary reporting of LERs is

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further discussed in Section 5.1.5 of this report.

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In addition, voluntary reporting is encouraged under 10 CFR 50.72, s

discussed in Section 4.2.3 of this report.

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McVever, the NRC staff censidered many of the voluntary repcrts

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submitted in 1990 to be required under 10 CFR 50.72 and 50.73.

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These included a manual reactor scram, ESF actuations, technical specifications requirad shutdowns, unanalyzed plant conditions,

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large spills, and common mode failures.

Submittals of such

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improcerly classified INS notifications er LO s in liau :_

j required reports do not meet 10 CFR 50.72 or 50.73.

Licensees ara cxpected

.c properly classify and rapcrt even u in accordance with these rules.

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l 2.10 Retraction /Cange11ation of Event Recorts i

h Licensees have expressed concerns about the counting of event j

reports, both ENS notifications and LERs.

The NRC staff has l

indicated that its interest is in evaluating the reported l

informat.on, not in counting the nuabar of events reported, While event reports may be formally withdrawn, the staff has i

l often found the information reported useful and has maintained the information on file with the withdrawal notation.

Licensees are encouraged to convert each report to a voluntary report rather than a retraction or cancellation.

If a licensee so chooses, an ENS notification can be retracted and an LER can be canceled using the same procedure by which the initial report was made The retractions and cancellations are further discussed in Section 4 for ENS notifications and Section 5 for LERs.

Sound, logical bases for the withdrawal or conversion to a voluntary report are to be communicated with the request.- Such actions receive staff review.

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I 3.2.1 Plant Shutdown Dequired by Technical Specifications 550.72 (b) (1) (i) ( A) 550.73 (a) (2) (i) (A)

' Licensees shall reoort: "The Licensees shall subnit a initiation of any nuclear plant shutdown required byl the Licensee Event Reoort on: "The coroletion of any nuclear plant's Technical plant shutdown required by the Specifications."

plant's Technical Specifications."

If not reported as an emergency under $50.72(a),_ licensees are i

required to report the initiation of a plant shutdown required by TS to the NRC via the ENS as scon as practical and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the start of power reduction.

Licensees are required to submit an LER if the shutdown is completed. W M " q U a we4 t\\ca s kr A. T/s <c uWed A+ d e um be,3u m M t44 cetu pk.k o w 6 M od e, Car. Discussion Tke veu.kv is cdv sak wbeviktal. Tk 4eMeVOwVC/PMMC. "E*5 This 50.72 reporting requirement is intended to capture thoseRff;.l.

events for which TS require the initiation of. reactor shutdown %

to provide thc4 NRC with early warning of safety significant 96enM.M

. conditions serious enough-to warrant-that th'e~~~ plant'Se~s Titsdown, h

For $50.72 reporting purposes, the phrase " initiation of any nuclear plant shutdown" is the performance of any actTon to start reducing reactor power to ashityr an operational qgndit3cj) or_

- mode _that requires the reactor to_be subcI_i.t_i_ cal, as a result of i

\\ a TS requirement- (e.g., - a limiting condition for operation- (LCO)

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action statement or Standard Technical-Specification 3.0.3, or i

equivalent).

This includes any meang_gLpswer reductions, such as control rod _inseM;1gn, b_oron concentration chances, or boiling water reactor (BWR) recirculation flow reducticn.

For $50.73 reporting purpos'es, the phrase "c_qmpletion of afly nuclear _ plant shutdown" is defined as the point in time during a TS required shutdown when the plant enters-the first operating _

' mode _1 hat _raquires_the reactor to be_.auberitiemi.-

(d( at,0200Aours adan(egers_an-LCO-acti'on~atatement-thaitd For example,y stat ~es,% restore the inoperable channel to operable status within-12 hours 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 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />.

An LER is required if the inoperable channel is not returned to operable-status by-2000 hours and the plant enters hot standby.

An *.IR i:., nc*.

quired. if a f ailura can bs :::r2cted bef:rn a clant is required to be in a shutdet.m condition and no other criteria in 50.73 apply.

The shutdown is reportable, however, if 21-

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the situation cannot be corrected before the completion of the shutdown or if the plant shuts down early to correct the problem.

Examples (1)

Initiatica of a TS Required Plant Shutdown The monitor alarmed for one of three safeguard equipment cabinets and the cabinet was declared inoperable.

The plant's TS required that if one cabinet is out of service, the plant must be in hot standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The licensee initiated a plant shutdown from full power and made an ENS notification.

The licensee made an update. ENS notification after the equipment was repaired, the cabinet was declared operable, and the power reduction'was stopped before completion of the shutdown.

An ENS notification is required because a TS required power reduction was started.

The update ENS notification is required immediately under 550.72 (c)'(2) (ii) to report the effectiveness of the response taken to the event.

An LER is not required because the plant did not reach hot standby'or hot shutdown.

(2)

Initiation and Completion of a TS Required Plant Shutdown When leakage around the primary containment ventilation l

exhaust dampers exceeded the maximum allowable. combined i

secondary bypass leakage rate, the plant'TS required the

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plant be in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.- The licensee commenced a reactor shutdown at 10 percent per hour and made an ENS not'2ication within 13l minutes.

The licer.see made update ENS notifications, when the plant reached hot and cold shutdown-'and the technical specification.was exited.

An ENS notificati.on is required _because'a plant shutdown was-initiated as required by-the-plant's TS.

This event also-is reportable under 550.72 (b) (1) (ii). as a degraded plant condition.. The update : ENS' notifications were made under 50.72 (c) (2 ) (ii) to report the effectiveness of the response taken to the event..An LER is required because the plant shutdown was ccepleted.

(2) 5hutdown Sefera cha 2nd c1 T3 Time Li=::

While at full reactor power, a plant's essential service watar-pu=p discharge check valve failed its monthly surveillance test.

Because repairs could not be completed Or:f: :"222 - M ::, ? r

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9 other compensatory measures.

Such time constraitt.$ are based on the safety significance of the component or system being removed from service.

Exceeding LCO action require = ants is prohibited.

An LEA is required if the conditions of an Leo are not met (e.g., by exceeding the permitted time constraints).

The LCO allows a plant a specified time interval (e.g., 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) to accomplish ev.rective actions (e.g., an orderly shutdown to either the hot-or cold-shutdown mode).

The staff is interested in the frequency of occurrence L.)d the TS involved in events in which a shutdown did not occur within the given time constraint.

If a plant is in a degraded mode longer than permitted by the TS, the condition is repartable even if the condition was not discovered until considerably later and the condition was corrected immediately after its discovery.

(3)

TS Surveillanca Requirements For tne purpose of evaluating-the reportability of dit pancies found during TS nurveillances, an operation or ton prohibited by the TS existed and is reportable if con the ne of actual equipment inoperability exceeded the LCo-allow cle.

It should be assumed that the situation occurred at the time of discovery unless there is firm evidence,-

based on a review of' relevant information, to believe otherwise (e.g., the equipment history and cause of failure),

l For missed surveillance requirements, the staff-is interested in the effectiveness of~ ensuring that i

surveillance tests are conducted within the required perives.

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 performed.

(4)

Design Features Design features of a licensed facility are-attributes such as materials cf constructien-and.gec=etric fostures which, if altered or modified, can have a significant effect on safety and are not covered oy items (1) througn (3) a bove.

Reportreility recuirements related to design featuras are included in other sections of 10 CFR'50.72 and 50.73.

l 35 Draft NUREG-1022, Rev. 1-t

(5)

Administrative Requirements, Including Radiological Controls, Required by section 6 of the STS, or Equivalent Section 6 of the STS, or its equivalent, has a number of administrativa requirements such as organi:stional structure;-the required 'humber of personnal on'shif tr the

-maximum hours of work permitted during a specified interval.

~

V of time; and the requirement to have, maintain and i=plement?

/,

N N. -e } certain specified procedures.

Failure to meet such i

administrative Whether it is r.requinaments_Ls_proliib'li~edibDlie TSl.

/

tm REk eportable as an LER depends upon whether it "a

results in a condition covered by the LER rule.

[f a X

[(0""* ',p"Yariance_from_the_ administrative.r.9quirements_of_TS re_s

)

~

ih"bp'erations or conditions

~ ' ' '

~~~

then the

,/

varia~nce"i~s~riportable. ~ prohibited by~the TS; L hwc

(

D.[1 Aa f._/ '

'\\/'U^vA-

-Radiolcig16al conditions and events that are prohibited by a

)

W W %' plant TS are generally reportable under the requirement 9 of 10 CFR 20.403 and. 20.405.

Sections 20.403 and 20.405 use k

/thereportingmethodologycontainedin10CFR5072and

_ f 50.*13.

Redundant reporting is not required.

(6)

Entry into STS 3.0.3 STS 3.0.3, or its equivalent, establishes requirements for 6ceal actions when an LCO is not met and no action statement is a Two c.

provided.

Entry into STS 3.0.3 is considered to be the gg action taken, as required, when operations or conditions 9 "*4*;

required by TS LCO action statements are not met.

Thus,

"" 1 until a plant is placed in a mode for which an LCO does not apply, the plant is

** \\ prohibited-by.JS.. /_ considered to)>e-ina condition-Entry into STS 3.0.3 for any reason or iupMLLy_a_ tion is re66rtiable u compliance is obtained. Mhe nfess a temporary ITalVeE~of~

A G a 2.

stafFis~ interestddin'thT

$$"Q Esquehefirie thir peFitic TS involved.

r s

qm 3.o4 ch ev10 v 4o TWOC. *Perodel 0*e MC- @Wde ^ g,'73 f,gg,y,fj y,e6c Hissed or Deficient Tests Required by ASME Section XI i Y "d*

(7)

Inservice Testing (IST) and Inservice Inspection (ISI) and by STS 4.0,5, or Equivalent.

Section 50.55a(g) of 10 CFR requires the implementation of an IST/ISI program in accordance with the applicable edition of the ASHE Code fcr those pumps and valves whose function is required for safaty.

STS Section 4.0.5 (or an.

squi nlent) covers thase tacting requiramants.

If an IST er 23! is not perf rmed when requirsd, or if ASME Sactic." "l inup 'acti:nc tact: 0; requirem(ents,nami.nti:ne; shev th:.

p One fail to meet the failures are reportable when they cause the associated syste=s required for safety :: be declared inoperable.

)

1 l

Dra:t NUR'1-10: 2, Rev. 1 36 l

1 (8)

Fire protection Systems When Required by TS When fire protection systems are covered by TS (e.g.,

through an Lco), they are within the scopa of tha LER rula.

Breaches of firn barriers required by TS and conditions that could prevent the required operation of fire protection j

featuros specified in TS are reportable conditions unless preplanned and covered by compensatory measures.

j Exaroles m%et uk cre w W d e A *

• L* M M*C

LCO Exceeded tu tco iwrNA 5 %O (1)

A licenses found a/mm-

.ce sum (wh Nec wo MtW'd#%;.w

.~ - e

.-.\\ ~ q a yju Yohonent with a 7-day Leolad

@pw~

silandb kasociated 8-hour action statement to be inoperable during a f

30-day surveillance test. Subsequent review indicated that the component was inadvertently assembled improperly during maintenance conducted 30 days previously and a post-maintenance test of the component had been conducted which was not adequate to identify the error.

There was firm evidence that the standby component had been inoperable for the entire 30 days.

~~~' 'L, An LER was required because the 7-day Lco'It'th"e'com mir tm r + TN / ~s statement time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> was exceeded.

had been made operable after the 30-day test and before the LCO expired, an LER would not be required.

(2)

Missed Surveillance Tests A licensee, with the plant in mode 5 following a 10-month refueling outage, determined that certain monthly TS-surveillance tests, which were required to be performed regardless of plant mode, had not been performed as required during the outage.

The surveillance tests were immediately performed.

An LER in required because the time interval exceeded the.TS surveillance interval, including extensions permitted by TS.

(3)

Entering STS 3.0.3 With essential water chillers (A)-and (B) out of service, the only remaining operable chiller (A/B) tripped.

This condician cauced :ha plan: 00 entar JT3 0.0.3 Jer i hour until chillar (A) was rest: red to cartica.snd the Ov2perature was ras:cred to witnin TS limits.

An LIR is required for this event brtcauri STS 3.0.3 was entered.

7 Craf NUR

3-1;;;, Rev. -1

= -.

___.m.,

r (4)

Administrative Requirements, Including Radiological controls, Required by section 6 of the STS, or Equivalent If a control room is operated with less than the required number of people on shift or lo operated with a requirad procedure that had not been properly approved, these operations would constitute a condition or event prohibited by the TS, and as such are reportable.

However, if a requirement in only administrative and does not affect plant operation, then an LER is not required.

If a change in the plant's organizational structure is made that has not yet been approved as a TS change, an LER is required.

The implementation of TS changes before NRC approval, such as deletion of a shift technical advisor position, is clearly operating in a condition prohibited by TS and would be reportable.

During a plant startup, a reactor water cleanup (RWCU) system isolation was initiated by a sensed high-differential flow.

This condition is identified in the plant's TS as a required isolation during the plant's present operational mode.

While trying to restore the RWCU_ system to operation, the system continually isolated from high temperature to the RWCU system demineralizer bed.

This RWCU system high temperature isolation was another isolation required by TS during the plant's operational mode.

The shift supervisor determined that reactor chemistry would deteriorate and eventually place the plant in an LCo action statement.

Therefore, the shift supervisor directed the RWCU system high-temperature isolation be bypassed, even though such-action was not covered by approved procedures.

The supervisor reasoned that the TS LCO for inoperable RWCU system high-temperature isolation permitted up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> before the instrumentation must be placed-in the tripped-condition.

Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the shift supervisor's decision, the jumpers were installed, the system was returned-to operation (once the system was started, the hot water causing the high-temperature isolation was pumped to-the feedwater system), and the jumpers were removed.

The installation without approved procedures of jumpers which bypass a TS required-actuation during modes when the actuation is required is an action prohibited byfTS and an LER is required, 1 licensee *siled t: impla:ent ndiatien pratarp-enhg required by-ghe TS.

Such failure resulted in or had a'high

" pres 6ribid~ W,its.-personnel exposures in excess :,(,.GC ~ ~ " -

' potential f 11m An LER is required under the requirements of 520.403 and this 550.73 criterion; one report should cite both requirements.

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. _ =. -

4 identified these types of adverse conditions, 4

management responsible for reporting until exhaustive evaluations but did not inforu were performed.

Management responsible for reporting should be promptly informed if there is reasonable belief that an adverse condition exists so that the condition can be evaluated for I

condition was acceptable.reportability even though further analysis might reveal th I

reporting requirements of $50.72 (b) (1) (ii)turther clarification of and $50.73(a)(2)(ii) are given below.

(1)

Plant Being Seriously Degraded A nuclear plant's components, designed to meet applicable NRC requirements, systems, or structures are functional requirements, satisfy the current licensingfulfill system basis, and conform to specified codes and standards.

i components,

systems, These with design margins and engineering margins of safety toor structu does not mean immediate failure. ensure that some loss of quality or func I

Additionally, many quality or functionality occurs, licensees add conservatism so t still maintained.

the margir.s of safety are I

The phrase " plant being seriously degraded" refers to a condition of a system, structure, or component in which l

as evidenced by decreases in the margins and conser 5

beyond that added by the licensee and not previously considered by the NRC in a safety evaluation.

test, Analysis, judgment, experience with operating events, engineering or a combination of these factors should be used to the point at which systems,to determine if margins and conserva structures, or components have become seriously degraded and reportable.

l Abnormal degradation of the principal safety barriers (i e the fuel cladding, reactor coolant system pressure boundary or the containment) caused by material chemical) or other (e.g., mechanical (e.g., metallurgical, probitos is included under these repo,rting criteria, electrical, operation) k

/.

(2)

Plant in an Unanalyzed condition p gRcry so n g y e d 1. F C gYgem y,; 3 Meu" The egetd 6 nd ugu M "AnunanalyzedconditionthatsignihEekicanI1'y,compromisesWa 6 nc de v m o n u tm hV plant safety" exists if (1) the conditionf' p system, or structureotentially3 ccadihto. " A l:o'hcvc affecting a component, is of more+than% g g minor,? safety significance; and (2) theconditiondo mould (a) increase the probability of occurrence or'tentially) V4 d e' */*_

consequences of an accident or malfunction of equipment th~e~ ; F # k. end/O" rem H3laeb N g(y g \\g to Nu l? E & / M.

4 3 P

p\\i nd /1, umJC V p.3 Draft NUREG-1022, Rev. 1 gg g

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i

a

}GREG-1397 defines current licensing basis to be "the ifRC requirements imposed on the plant that are currently in effect....The licensing bases are contained in NRC regulations, plant technical specifications, orders, licansa conditions, exemptiens, (HRC statf catety evaluations), and licensee commitments centained in the final safety analysis report, and other docketed licensing correspondence including responses to bulletins and generic letters."

In addition to the current licensing basis, other design constraints, which are implemented to achieve certain economies of operation, maintenance, procurement, installation, or construction, identified in NUREG-1397 are:

system functional requirements (including specifications) conformance to accepted industry codes and standards...

e vendor intertace requirements [ including approved e

operations and maintenance (o&M) other design considerations that could be classified asmanual recommendations w

" generally accepted good engineering practice" If one of the following conditiens exists, the plant is considered to be outside the bounds of its design basist a structure, system, or com intended safety function (s)ponent is unable to perform its a structure, e

system or is specific _value or ra,_nge'componentofsvaluer tha_ exceeding the,.

~ '

t were~ chosen for s

,conprcilling parameters as its reference bounds f or design,

g

~N MA uct J tpMade (e entry into STS 3.0.3, or its equivalent as dise.uned o n %% ; -}

w.-w/

y y

y (4) plant Condition Hot Cover,ed by o/.perati,ng and'EYaergency procedures For plant conditions not covered by the n'

.t's operating or emergency procedures, an ENS notificati.

and LER are required for either of the following:

• the condition 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. " Quality Assuranca ? : gram Raquiraman: ";

50 3pplicabla :pers-ing :r ameriency pr :ahre exina and Too

)

[8ideexistingrequiredcoerating

.Sa(e;y-relatede,quipzen, m4WcNt'dMinor *.!rfvpig3 3,

=C W 1000

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s1 nificant valve 9

" misalignments are

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Dra4.t NUREG-1022, Rey, 1 45 of Sy'hm W tra Ive lio c-p.

Exanoles (1)

Plant Boing Seriously Degraded Reportable Events or Conditions e

physical deformation occurring to components, systems, or structures (including supports) or causing inoperability of equipment that is important to plant safety that could reasonably have resulted from water hammer fuel cladding failures in the reactor or in the storage pool that exceed expected values, that are unique or videspread, or that resulted from unexpected factors cracks and breaks in piping, the reactor vessel, or major components in the primary coolant circuit (e.g.,

steam generators, reactor coolant pumps, valves) that have safety relevance, including significant welding or material defects an inadvertent loss of a significant quantity (>100 gallons) of the reactor coolant system (RCS) inventory as a result of a mispositioned valve, a main steam safety / relief valve failing to reclose during testing while at power, or an unknown cause a reactor trip breaker failing its trip bar lift force measurement test as a result of a significant design, maintenance, or test problem containment Integrity Lost During operation o

While at 100 per cent power, during the performance of a surveillance test of:the containment door interlock, the inner containment door failed open allowing a direct path from the containment,to the atmosphere for a short time.

An ENS notification is required because of the loss of primary containment integrity, a serious degradation of a principal safety barrier.

An LER is required.

Local Leak Rate Test Failures During Operation A '0 Cr? 50 Accendix J, 1:021 ' e a k. rate test d3:Grmin21 that a containment purge =exnaus: 11ne penetra;aca aus 12aking at 0.7 La.

The-t:tal Type 9 and C leakage was 0.85 La, which exceeded the TS limit of 0.6 La.

The licensee reportec tnis in an ENS notificatien. Tha licensee made an update ENS notification when a TS

2:uired 2nu d:wn vna bagur cr/ar:1 50ur: 13 Sir 2nd 3r Draft NUREG-1022, Rev. 1 46 i

l t

i Unusual Event was declared.

The licensee made updato ENS I

notifications when the plant shut down and the Unusual Event van terminated after repairs to the valvas vera made

)

and the lesh rate was within TS limits.

An EMS notification is required under this criterion because of the degradation of a princieel safety barriet (primary containment) during operation, as evidenced by the leakage exceeding TS limits, requiring a plant shutdown.

An immediato update ENS notification was required by $50.72(b)(1)(1)(A) of the initiation of the plant shutdown and by 550. 72 (c) (1)-(i),' 550.72 (a) (1) (1) of the declaration of an emergency.

The notification of the termination of the emergency was required by

$50.72 (c) (1) (iii).

Although an LER is not required under

$50.7 3 (a) (2) (1) ( A), it is required under

$ 50. 73 (a) (2) (1) (B) and $50. 73 (a) (2) (ii).

i

• Degraded Reactor Head Studs i

Plant technical staff was notified by engineering that destructive testing of a reacto sad stud revealed the stud hardness was outside th hardnnsa numbers.

' equirements by eight Cd5(yf\\

The condition is reportable under two reporting criteria:

~

first, as a serious degradation ~of the RCS pressure boundary, and second, basis of the plant.

as a condition outside the design (2)

Plant in Unanalyzed condition

• Reportable Events or conditions spills that create conditions.that_could affect' component operability, qualification, or design life because of

^

a) the extent-and depth of water that floods or wets?

components not designed to be submerged or wetted-and that' restricts personnel access-for safety-related functions-b).

higner-3 nan-analy:ec :e:peratures anc humioity wnen the water is not-, valen degrsees components and can result.in failures c)-

- radiation: levels above-the area design-basis that dagrade componente seritus ECS. tarpersture :

. ; rec:uret tr:rsiantsi 2x v3 ding _to;;;n-':rntsenni:2. spe:Li;;;t;:ns limits, t

_47f Draft NUREG-1022, Rev. 11 i.

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-e

' " " ' " " ~ " " " ' " * " '

r i

any significant deviation in either direction (beyond the allevable range) from a calculated critical position during reactor startup, even if a reactor trip does not occur and subsequent analysis adequately explains the anomaly, for example a) deviations caused by unexplained phenomena, improper rod position, unlicensed or improperly supervised trainees, are reportable b) deviations caused by routine calculational uncertainties are not reportable a containment spray discharge line, analyzed in a dry condition, containing water from system testing and resulting in an unanalyzed seismic condition EDG Room Temperature Slightly Exceeds FSAR e

The FSAR specifies the maximum permissible ambient air temperature for the emergency diesel generators is 95

'F.

on a su=mer afternoon ambient air temperature was 96

• F.

This represents an unanalyzed condition.

If a priority engineering judgment indicates that the effect of the high ambient air temperature is inconsequential, the situation does not represent a reportable unanalyzed condition.

(It also is not considered outside the design basis of the plant because it is a minor variation.

Thus it is not reportable under this criterion.)

If the engineering judgment indicates that the effect is not inconsequential, it is reportable.

(3)

Plant Outsida_ Design Basi f

\\

3-g-

~~v 4",

h Untested containment Isolation Valves 4

nttMIU' Ag 4/

A licensee determined that six normally open valves used 1

for containment airlock cycling were containment isolation j M i $bO, f valves.

The valves, which had not been leak rate tested, (

g

((lo g ere closed to ensure containment integrity.

j E$fN

/

This-event is reportable because equipment had not been /

p f MV operated,-analyzed, or tested for the safety-relatea

/

4yy function i: was required ::..ssrve 2nd containment:

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intaar,:v vas eslied into p'asti:n, Vq,/

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+

Md

• Service Water Sys*em Leaks ppuAltrAevd5. 70N(ts) 376 /

i<A 3 D /*7-(W O b 3' A -licensee experi2nced degratchn-I the ser" ice vster C

systempipingovertimeandgumerou pinhole leaks or Draft NUREG-1022,- Rev. 1 48

-e.

,-..%,y wa-e y

J radios), or more importantly, the capability to alert a large segnant of the population for a period of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or more veuld varrant an immediate notification.

Loss of connuhicar166Pearability

/

k A major ^1oss of communica,tions capability for other than a short time (less than i hour),2ay typically include, but not be limited tol the partial loss _of)the ENS, dedicated telephone commuhication-1-ink to a State or a local government agency and emergency offsite response facilities, in-plant paging and radio systems, or commercial telephone lines.

Ixaltoles Loss of E=ercenev Assessment Canability (1)

Loss of Emergency Operations Facilities (EOF) computers Power was lost to the local EOF air conditioning and computer when a transmission line was lost.

When the co=puter-room temperature exceeded 78 F,- the computer tripped as designed.. Concurrently, the corporate EOF computer was out of service for-planned work on that facility's air conditioning system.

Both EOF computers. vere out of service for several hours. The-technical support center computer remained operable throughout the_ event.

An ENS notification is required because of-loss of use of the EOP.

No LER-is-requireji. '

V

'N n

[

Loss of Plent Computer Data Acquisition System (DAS)

I The plant computer lost its DAS although the safety i

parameter. display system and other control room. indications remained operable.

The licensee considered this loss of the

/

DAS to be a major degradation-of the. plant's-emergency f

assessment capability = The: licensee initiated investigation.

and repair efforts, informed the' NRC resident : inspector, and(/:

made~an ENS notification within an hour of'the loss-of:the:-

-DAS.

The licensee _also made a follevup callito the NRC operations center saveral-hours-later when the computer was 1

\\>

restored to. service.-

/ -

N i

L An ENS notification is-required because the-loss of tais f

1 l:

:put u vas 10:nsider# by tu. :.1:n.c n to to i mj er-l-et: f of-assess =ent-ca L

~ Q y A._ pability.' No LER is required.

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t Less of offsite Resoonse cannbility (1) plant Access Roads closed by stor:

The local sheriff notified the licenses that all roads to and from the plant were closed because of a snow storm.

licensee had two full shift crews on. site to support plantThe operations and no emergency declaration was made.

The licensee notified State and local authorities of the situation and made an ENS notification.

The licensee deactivated its station isolation procedures after the storm passed and the roads were passable.

An ENS notification is required because the sheriff's road closing may prevent the plant staff from staffing the TSC, etc., or from fully responding to some emergencies.

A follovup ENS notification is to be made when the situation has been rectified, if periodic updates were'not specifically requested per $50.72 (c) (2) (ii).

This event is also reportable under $50.72(b) (1) (iii).

No LER is required.

(2)

Loss of Public Prompt Notification System ENS notifications of the loss of the emeroency si tone alert radios vary according to the lleensee'rens or s locale and interpretations of " major loss" and have included:

• 4 of 37 offsite sirens reported inoperable by local fire department (licensee procedures defined major loss as > 10%)

12 of 40 county alert sirens disabled for several hours because of loss of power as a result of severe weather

• 28 of 54 alert sirens reported out of service for an hour as a result.of a local ice storm and a roturn-to-nervice estimate was unknown-

• All offsite emergency sirens were found inoperable during a conthly test taken out of' service for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of repair inoperaole because. control panel pcvar vas 10st f:r an

. unknown perici Inoperaole because the county radio transmitter failed for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> An IM3 notificati:n is-required because of the major loss of the public prompt notification system.

An LER is not required.

Draft NUREG-1022, Rev. 1 62

L2Ep.of_ 00- un_ications Cacability (1)

ENS Teleph0ne Prcblem The licensee deter =ined, during the monthly ENS surveillance test, that the technical support center ENS telephone was inoperable for over i hour.

An ENS notification is required because of the loss of the ENS telephone.

No LER is required. If the NRC Headquarters operations officer notifies the licensee of an inoperable ENS line, that discussion constitutes th. required ENS notification and no further notification is necessary.

(2)

Loss of Direct Communication Line to Police The licensee contacted the State Police via commercial telephone lines and reported to the NRC operstions Center that the direct telephone line to the State Police was inoperable for over 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

The licensee notified the NRC operations Center in a followup ENS call that the line was restored to operability.

An ENS notification is required because of the loss of the direct telephone line(s) to various police, local, or State emergency or regulatory agencies.

The follovup ENS notification was required by 550.72(c) (2) (ii) after the line is restored.

No LER is required.

(3)

Loss of In-Plant Paging System The licensee removed its in-plant paging system from service for modifications for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> while the plant was in cold shutdown, without establishing compensatory measures that ensured communication with personnel during an emergency.

An EMS notification is required Lacause of the loss of the in-plant paging system without sufficient compensatory measures, if the licensee relies on its use during an emergency.

A follevup ENS call when the system has been ret,urned to service is required per 550.72(c) (2) (ii).-

If the system loss is anticipated, i.e, being removed from service for planned maintenance, the ENS notification should be made before its removal from service, No LER is ret'ured.

63 Draft NUREG-1022 Rev. 1

3.2.8 Internsl Threat to Plant safety S 5 0. 72 (b) (1) (vi) 55 0,73 (a) (2) (2)

Licenseen shall report: "Any Licensees shall report:

"Any event that posen an actual threat to the safety of the event that posed an actual nuclear power plant or threat to the safety of the significantly hampera site nuclear power plant or personnel in the performance significantly hamperad site of duties necessary for the personnel in the performance safe operation of the nuclear of duties necessary for the power plant including fires, safe operation of the nuclear toxic gas releases, or power plant including fires, radioactive releases."

toxic gas releases, or radioactive releases."

If not reported as an emergency under 550,72(a),

required to report such an event or condition to the NRC via the licensees are ens as soon as practical and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Licensees are required to submit an LER within 30 days Discussion These criteria pertain to internal threats.

external threats, The criteria for described in Section 3.2.5.S50. 7 2 (b) (1) (iii) and 550.73 (a) (2) (iii), are

Fires, only reportable-threats or hindrances to safe operation of th plant.

They were included in the criteria as examples oql were.not meant to be_an exclusive list of reportable threa,y~and-Additionaltypicalexamplesofconditionsreportabis[,underthese ts.

criteria are listed below.

1. ggy in-plant (radioactive) spills or floods

~ TC% A e

smoke from failed electrical equipment e

y like of solid, liquid, ignition, detonation, burns, combustion, explosion non-safety-related nuclear process systars er elsewhereor gaseous materia hi

/gAbave e%f carben renet:id a[:: "M '-

ctsT sc W urbc5

-b umocca g' (Ldischarga g "

• n_ dioxide c( halen systems f0dW6Sh0dd operational problems 7 e.g;., d V\\t,Ne-\\fTM X_

e signa:1 cant auxiliary transforter-cooling during operstien causingthe loss of =ain er.

in cdi1:2

$t ace,

wer'recue:icn:

__s_m an: cers:.rel ev2cu : :nc bot ri 4h(CAh.

Draft NUREG-1022, Rev.

1-64 '

n

t because of an explosion hazard that could cause transformer, switchyard, or hydrogen fires, and loss of offsite power).

To clarify the intent of these criteria, the specifi: conceptc are explained below.

Threat The phrase "an actual th'reat to the safety of the nuclear power plant" is a reporting trigger.

An actual " threat" is an imminent source of peril to the plant.

Such an event is a source of i=pending peril to the safety of the nuclear power plant or its safety-related or other non-safety-related-equipment, or it could have already degraded the plant's safety margins.

The NRC is interested in real or actual threats as opposed to threats without credibility.

Broad Scope The scope of the regulation is broad, covering more than just safety systems.

The regulation refers to "the safety of the nuclear power plant" and "sufe operation of the nuclear power plant," which covers not only many systems found in the reacter building, but also most of those-i systems in the turbine or auxiliary building.

Significant Hampering of Site Persoanel

"""C

• F The phrase "significantly hampers site personnel" ranges O* b from hindering _herrsTming precautionary measures, or inter.f er.ingwi~th'(iver, ciliciag additional MN or@(Qail tice such'bss -

% ke (/ radiation work per=ith yrotec_t_iye_og_anticoat.amina11pn )

-clothing, cgvistilta, b u riXFr"g etr7~Ta rib-s elf-con t adu adM 4 ts gg f..breaHEns a~pparatus.in areas not normally so encumbered) to, and including, prohibiting or preventing automatic or manual 450 \\md actions.

I McVen % huisa vec. /Efodly.

3'To be reportable, an event need not prevent ~ site personnel from performing their duties--it is only necessary that they be significantly hamper,ed, hindered, or interfered with.

If the event caused a large portion of a major building to be-contaminated, evacuated., flooded, or filled with smoke or gas, personnel may be able to perform their functions, but

' they are significantly-hampered in their performance.

If the condition makes performing routine functions in.cne nuclear pcwer plant significantly more difficul:-and i: i s something more than a routine nuisance, it is reportable.

This part of the criteria includes only those events that 3;gnifican:iy namper the ability ci si:a pers:nnel n

performance of duties necessary for' safe operation.

L i;;.9:H3 t:0 -;; 0 engineering Md 22n: ir datermining ;f 65 Draft NUEIG-1022,-Rev. 1

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site personnel.the event crosses the threshold of significantly ha The safety significance of the equipmentg involved, the potential effect of its failure on the plant i

eperation and/or challenges to safety systems potential need for immediate or periodic perso,nnel access and the nhould be factors in determining the significance of an Significant hampering of site personnel in the plant areas is also reportable, the reactor transients initiated by secondary systembecause it anomalies.

Plant Modo actual internal threat to a plant; plant mode may be co n

to use engineering judgment on a case-by-case basishowever,. licens 1

plant is shut down is unimportant and not repo Do not voluntarily reporting _if the event has potentia implications to another plant or to another mede Evacuations L

of rooms or buildings and,In-plant releases are reportable _

as a result n

plant personnel to perform necessary sa,fety functions isthe abilit significantly hampered.

waste releases, or the disturbance of contamina s.

j evacuation of an individual room until the airborn concentrations decrease or until respiratory protection devices are used, are not reportable unless the required evacuation affects the major part of a building or facility Any evacuation of multiple rooms or a significant portion a large area, such as1the containment, reactor auxiliary i

of turbine radwaste, or spent fuel pool buildings, as_a res, ult of an ac,tual fire,' spill,

flood, is~ reportable.

gas or radioactive release, A precauti: nary evacuatien is an evscuatier that criar t: be prudent, but vac nada because the condition causing cencern did net actuallywas exist.

Although generally not reportable, precautionary evscuationc are-reportabla under 550.72 if the causative condition is not fully investicated or understood within the 1-hour rep 0rting limit-(e.g., radiani':n :: nit:rs alar - tit grno samplac had not caen proca 'ad;.

Draf t HUREG-1022, Rev.1 66-

o L

Evacuation of multiple rooms or a.significant portion of a large i

area is reportable, as previously discussed.

& $ ";b A 0 b tA O In-Plant Scill/ Flood Threat

[-, -, becoww k n-plant spills in excess o'f 55 gallon]g or floods C4iftVIA Significant i have been under reported by licensees in sode-instances.

These

{ hAo 4.

I events are of interest to the NRC because of the potential for equipment damage, significant hampering of site personnel in the performance of duties, implications for environmental qualification, intersystem loss-of coolant accidents (LOCAs),

precursors to more serious events, or the potential for fuel becoming uncovered.

In-plant spills-or floods are-reportable if any of the following, or other typically significant, consequences occur The leaking system is a' safety system and potentially involves an intersystem LOCA.

This does not include small packing or gasket leaks, but does include events in which the packing is blown out.

If.

leaks cause a significant flood, are located in an unisolablo section of the primary system, cause significant eroding of piping or bolting, or cause personnel injury or hazard, they are reportable.

Small leaks that directly affect other equipment,-normal operations, or cause

- evacuations are reportable.

The. intent is to have significant spills and floods reported.

The leaking fluid ~is radioactive and contaminates a significant area, contaminates several individuals, or significantly contaminates one individual.

The leaking fluid is not radioactive, but is-in a vital e

area, and potentially affects vital equipment.

- o operational compensatory measures are required,-such as a power-level decrease or equipment. operation swap.

1 l

l An ESF or safety. equipment is rendered-inoperable.'

Electrical equipment.was wetted dovn, such as from the containment spray headers.

Flooding. hampers operations personnel inEperformance.cf tc. air d..;as - (e. g., flo: ding ;n axcass cf 'surp p' amp capability,-a depth of several_ inches on the floor, contamination requiring new access control measures, or electrical hazards).

=

Draft NUREG-1022,5Rev. 1 69-

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(1)

Main Generator Excitor Fire The licensee reported a fire in the main generator excit housing.

The reactor was manually tripped and taken to cold or shutdown.

The station fire brigade soccessfully extinguished the first no offsite fire-fighter assistance was required.

environment via the turbine building. Smoke from the fire was releas radioactive releases or injuries to plant personnel.

There were no An ENS notification is required because the fire threaten d the safety of the nuclear power plant and significantl e

hampered personnel in the safe operation of the plant (i y

the fire was sufficiently severe to threaten the loss

.e.,

offsite power and require a manual trip).

of-required to submit an LER under both 550.73(a)(2)(x)

The licensee is 550.73(a) 2) (iv) manual rea(ctor trip occurred.because an actual threat was posed and and (1)

Control Room Fire With Unit 2 operating at full power, a-fire started hand switch in the control panel for an auxiliary'feedw t at a (AFW) pump trip / throttle valve.

a er solenoid for the valve, located in the AFW pump ro,om At the same time the smoking.

with a portable fire extinguisher. The solenoid stoppe was smoking after the circuit fuse bisw.

notify the fire. brigade. leader by radio pager of the-s

, or condition.

of the overspeed trip mechanism on the valve actuatorTh result of-personnel errbr.

, as a For corrective actions procedures a,nd instructions were revised, maintenanc post-maintenance testing, and fire rep,orting electrical trip was redesigned.-

and the remote-the event was not a significant safety hazard to thThe licensee judged that and-therefore was not reoortable; however, the licansee nt e pla auc 1 ted a voluntary LER s menth late.

Making ENS or LER' voluntary does not test the esquiremen. reports of a reportable event a fire is determined to-have been a saf aty threat u!!ar thts of :10 C fact, required reporting is necessary.

e Tht event is raccrtabla becausa it

-.canaea:s acti:ns, t 33 well

?.3 the nreatened pl' ant safety.

Other_ centrol Draft HUREG-1022,-Rev.

1

'70

O actuations of ESFs sometimes provide insights into systems interactions and system dynamics that testing does not disclose.

The guidelines also define EST systems (including emergency po.er), RPSs, and actuations for reporting consistency.

Definitions (1)

ESP Systems ESFs are defined to be those nuclear power plant systems that function to mitigate the consequences of postulated accidents.

Postulated accidents are generally identified in plant safety analysis (e.g., Chapter 15, " Accident Analysis," of a_ plant.'c final-or-updpted safety analysis report,(SAR))T eM p 697 Nom e.gctAAclC' h oAczto OY,"

J Esp n ped iW g/ f components or sydores arek. Ihc.h plut dedd 5fm b @%

aken credit for in safety analysis, these compt;nents or systems are considered to his g'

(' ESFs for reportability purposes.

Many, but not necessarily Ey jf f

all, ESF systems are identified in Chapter 6, " Engineered

' ')

Insomeinstances, components _{

Safety Features," of an SAR.

J C-or systems taken credit for in safety analysis afg_ht not be specifTed as Eing ESFs but are considered as such for

' "M

\\ jeportabilltyJ urposes.,

T!)e._ intent _of t6I D A_to_Achiere YM*

co"caraM e_ reporting among_all_ plants.

For older plants

,Mkisisn#:

N

/. that do not conform to Regulatory Gufde 1.70, " Standard ov,5 ;pd Format and Content of Safety Analysis Reports for Nuclear 1, Powerplants,"thisinformationmightbefoundinother,-Q'g%

,y (chapters of the SAR.

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Tabli~2 contTins~a iiarlial-listitif of typical ESF systems 6, \\ w1 that, if taken credit for in safety analysis, are subject to reportability.

Equivalent plant systems with different d'

names are to be considered ESF systems for reportability.

As Table 2 is only a typical listing of ESF systems, licensees should provide site-specific lists of ESFs to their staffs for use in reportability determinations.

(2)

Reactor Protection Systems RPSs are defined to be those nuclear plant systems that function to shut down (i.e., trip or scram) the reactor, including RPS sensors, power supplies, logic, bypass circuitry, hydraulic scram systems, and reactor trip breakeru (or their equivalents).

l L

Tne NRC statt' recognmes Inat some plants have not previously reponed actuation.s at iome of in: EF ces de F3nR Jesgaaucn3 c: E5F eyJp:neni.ane3 g.g.,

l emergencv diesel generators).

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i TABLC ? TTP! CAL [1F SYST[WS f.*e'ye"cy (c'e (colle; Syste*: (ICC$s) for pressWet2ed mater reactors (Isis);

reacter coolant syste? accumulators e

baron injection system e

hig's, intermotate. and low head injection systems, includ!ng systems for charging usteg e

centrifugal charging pumps. safety injection and residual (decay) beat rareval and their water sources r

associated valves, piping, lestrumentation, interlocks, punts, tanks. and necessary heat tracing e

For belling water reactors (BWRs):

high and low pressure core spray systems and their ester sources e

high+ pressure coolant injection system, feedwater coolant injection system, residual heat removal e

system, and their water sources isolation condenser system. reactor core isolation cooling system e

autorNitic depressuritation system e

associated valves. piping, instrumentation. interlocks. punes, tanks, and necessary heat tracing e

(,ontainrent Systems containment and reactor vessel isolation systems e

containreet heat reaioval and depressuritation systems, including the containment spray and e

aoditive system and the fan cooler system-containment air purification and cleanup systems e

containment combustible gas control systems, including hydrogen recombiners, igatiters, nitrogen e

inerting systems, and contairrent atmospheric dilution systems i

fet standby gas treatment systems e

Heating. Ventilating and Air Conditiont'ng (HVAC) Systes for the Control Room and Fuel handling Areas 1

PWR Austliary Feed ater Systems llectrical Systems I

emergency at electrical po ee systees.' including emergency diesel generators ([DGs) and their e

associated support systems (even if classified as an essential auxiliary support in the plant's

$4R), and B.R dedicated Otvision 3 LOGS and their associated support systems :

actbation and control systems (inclusteg associated interlocks) for engineered safety feature e

(($F) systems 4

tssential Auxiliary Support lystems Awtiliary su Cort.syHe*s are.those systeas t*'at see accessary for UF systems;to'te capable gf Te'fc* ming tPetr spectited functions and trat receive an actuation sigmal (e.g,c a s.afety injection f

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For guidance on reporting ATWS actuations, see " Anticipated Transients Without scram (ATWS) System Reporting" at the end of this " Discussion" section.

i (3)

Actuation of an ESF or the RPS Actuation of a system or component of an ESF or the RPS is defined as either Tkreskdd receipt of a signal (s) in the plant's protection system e

sufficient to satisfy the protection channel

&cc tcQ.

coincidence logie necessary to activate the ESF/RPS gamec system or component, independent of whether the ESF/RPS q er g uj W system or component operates hht.V EcI5 G-LOM deliberate or inadvertentg etic manuaLor automatic)-

e or plant conditions that(1helpy activat fie~ESF or RPS Ci>cd system / component without h e rt k coincidence logic _ being satisfied _ ec. tion _ghann*L (e.

J act3vation of_a_taftty_iniention_ pump.g., manual

,_an electrical 640S, wq jumper being used to start an emergency diesel a.c.muhagenerator, or set point drif t causing a BWR main steam safety / relief valve to open)

{ajic"\\)a\\de (c.wthg or (oc4((3 ? 7hc M4ve54cSdeuld Md k (4)

Valid Actuation--

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( 40 4 v m e l h v oup Valid ESF/RPS actuations are those that are (a) b IC3Dh4 automatically initiated by the measurement of an actual:

physical system parameter that was within-the established set point-band of the sensor that provides the signal.to the protection system's logic _(whether or not the~ESF functions properly or a design basis need exists) and (b) manually initiated in response to plant conditions.

(5)

Invalid-Actuations-Invalid ESF/RPS actuations are those not; considered " valid'?

as defined above.

Reoortability of-Events l

All ESF actuations, including actuations;of the RPS,_are

~

reportable regardless of the plant operating mode _or power 11evels or the significance of the structure,-system,~or.. component that initiated the event or. Whether initlated manually :::

automatically.

The !act that-the safety analysis assumes that an.

ISF system.will actuate automatically under cartain plant conditiens.dces not preclude the need-to report such actuations.

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The following exceptions apply.

(

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Actuations that result frem and are part of (1) sequenceduringtestingorreactoroperation(theprepl(nYed

~

This implies that the procedural stop indicates the specific-EST or RPS actuation that will be generated and control room personnel are aware of the specific signal generation before its occurrence or indication in the control room.

However, if the ESF actuates during the planned operation or test in a way that is not part of the planned procedure, such as at the wrong step,toya.Vlg V? v^0debportabig'tVV'IE C> "V\\

that event is r m Ts e N o t" lnvaliclkc,tuation (2) CaroperiytreRo@gronuservic0 if all requirements of plant w;l1

.that_ occur when a system has been (AC3e Uca procedure Ffor removing equipment from service have been This would include required clearance documentation, M0b met.

g g-equipment and control board tagging, and properly positioned valves and power supply breakers.

RPS/ESF Component or System Failure If the actuation involved a component or system failure, in addition to reporting the event under these reporting criteria, it also should be evaluated for reportability under other 10 CFR 50.72 and 50.73 criteria (e.g.,

as a single failure that prevented the fulfillment of a safety function, a common-mode failure, a degradation of the plant, or an operation prohibited by the technical specifications).

If the actuation involved a component failure that is reportable within the scope of the nuclear plant reliability data system (HPRDS), it should be reported to that system as noted in the Statements of Consideration for 10 CFR 50.73.

Anticinated Transients Without Scram (ATWS) System Reoortina ATWS is defined as an expected operational transient accompanied by a failure of the RPS to shut down the reactor.

ATWS accidents are a cause for concern because they could lead to severe core damage and release of radioactivity to the environment.

Section 50.62 of 10 CFR requires that ATWS mitigation systems function as a backup for RPS and that they initiate specific ESF system operation, as needed, while-minimizing inadvertent scrus or chal'.ences to other safety systems, Therefere. A ~~G actua~ ions should be reported under these criteria.

The guida'nce-given above for RPS and ESF definitions, reportability, and axceptions, also applies to the reporting of ATWS system automatic, manual, or inadvertent actuations or failures to actuate.

Draft NUREG-1022, Rev. 1 84

c Examnies (1)

RPS Actuation

(

The licensee was placing the residual heat removal (RHR) system in its shutdown cooling mode while the plant was in hot shutdown.

The BWR vessel level decreased for unknown reasons, causing a RPS scram and Group III primary containment isolation signals, as designed.

All control rods had been previously inserted and all Group III isolation valves had been manually isolated. -The licensee isolated RHR to stop the decrease in-reactor vessel level.

This evant is reportable within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> under this criterion because the RPS scram and primary containment isolation signals were valid and the actuations were not part of a planned procedure.

The automatic signals were valid because they were generated from the sensor by_ measurement of an actual physical system parameter that was at its set point.

However, this event also is reportable within 1 hour-under $50.72(b) (1) (ii) because the primary coolant system-was seriously degraded when the water level decreased as a result of unknown reasons.

An LER is required under both 550. 73 (a) (2 ) (ii) and 550.73 (a) (2) (iv).

With the BWR defueled, an invalid signal actuated the RPS.

There was no component operation because the control rod _ drive system had been removed _from service.

This event is not reportable because the-system had I

gg g, been properly removed from service and the RPS signal

""A

~

%f cy ei &

wa.s INc h the control rods fully inserted into-the. core and 4 h u k e. /

the RPE_prsperly renvmLfr.o_m_ service. an invalid

%gm signal actuated the RPS, but the closed reactor. trip wed wd breakers failed to open.

Even.though this event is'not h u e. b e4w I reportable under this criterion, it is reportable under mguA

/

other criteria,.. for example,--550.72 (b) (2) (iii),.

4o Lpe w.

S50'.73 (a) (2) (ii) - or (a) (2) (v), because fulfillment' of - a -

Aho,-I f RP5

. safety-function could-have been prevented, the-plant yevacoed Fm was seriously degraded, or shutdown of the-~ reactor _ _

ScvWCc Pftf dcould-have > been. prevented-if the plant had been g kleggjd[/tMd5

perating, AdygVevE a

• fo n D $ f N d I b g h M[ 3 3 g,, gE t 1 M U e M W * )-

92) ofb4vch( Ns.

A rod block that was part of therplanned-stprtuo procedure i

occurred from the rod block monitor, vnicn is classified as-a portion of the RPS orias an--ESF.;

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l This event is not reportable because it occurred as a part of a preplanned startup procedure that specified certain rod o

blocks may occur. dity anomaly or inadvertent criticality Ybwever, if it was caused by a significant reacti an ENS notification and LER are required.

(1)

Emergency Diesel Generator (EDG) Starts The EDG-automatically started when a technician-5 e

inadvertently caused a short circuit that de-energized an essential bus during a calibration.

An ENS notification and LER are required because the ESF actuation _(EDG auto-start) was not identified at the i

step.in the calibration procedure being used.

After an automatic EDG start.and_for unknown reasons, e

the emergency bus feeder breaker from the EDG did not close when power was lost on the bus.

An ENS notification and LER are required because the EST actuation logic for the EDG start was completed, even though the ESF function was not completed.

I i

EDG starts from certain anticipatory 1 signals--(e.g.,

o loss of offsite startup power sensed on the startup feeder breaker) are not reportable if no credit was taken for the anticipatory.EDG start feature in safety analysis, and the EDG did not load onto;the vital _ bus as a-result of a subsequent undervoltage condition on the bus (a valid ESF signal).

1 (4)

Reactor Trip-and Auxiliary'Feedwater (AFW) Actuation

[

A PWR tripped from 92-percent power, and the-AFW system actuated because-a steam-generator low-low level occurred when-a main steam isolation valva (MSIV) closed.

All systems operated as designed and the unit stabilized in mode 3 (hot standby)'.

The= licensee 11ater determined that a blown fuse caused theJMSIV to close.

'An update ENS-notification van ~made 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />'atter the reactor trip.

An ENS notificationJis required within' 4= hours of. the reactor trip-or_ESFiactuation, whichever occurred'first... In; this case, the111censee'made an ENS notification within 1 hour: of _ the reactor: trip, which< neetsithe intent and explicit _.requiremente of reperting_cuch events as scon'asi practical.

3 era EST-(A7W and MSIT ani R?s actuati:ns.

toccurred1and are reportable'within-the7 single notification.

Regardless:cfn hetherrany expected E3Ffactuations are listed w

in emergency! operating proceduresc they areLto be reported during tne ENS notification.

Update = reporting of'the-cause of'a reactor trip is always encouraged.

An'LER is'requiredL 1

LDraftLNUREG-1022, Rev.-1

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(5)

Preplanned Manual Scram During a normal reactor shutdown, the reactor shutdown procedure required that reactor power be reduced to a low power at which point the control rods were to be inserted by a manual reactor scram.

The rods were manually scratmod.

This event is not reportable because the manual scram results from and is, by procedure, part of a preplanned sequence of reactor operation.

However, if conditions develop during the process of shutting down that require an unplanned reactor scram, the RPS actuation (whether manually or automatically ~ produced) is-reportable'v,ia ENS _,,N 1

[notificat' ion and LER.

N' s c c. com

-% N Actuation of bm m t c W {nt During Testing N

g(6) rong Compon During curveillance testing of the MSIVs, an operator

/

j incorrectly closed MSIV "D" when the procedure specified

(

closing MSIV "C."

This event is reportable because the EST actuation that l'

occurred (closing of MSIV "D") was not specified in the step 1

(

of the proceduce being used.

,3 (7)

Control ~ Room Ventilation System (CRVS) Isolation

~~~

While the CRVS was in service with no testing or maintenance in progress, a voltage transient caused spiking of a radiation monitor resulting in isolation of the CRVS, as designed.

This event is reportable under this critorion because neither exception (1) nor (2) notification and LER are requiredabo y apply.

An ENS (8)

Reactor Water Cleanup (RWCU) Isolations l

l The RWCU isolation valves closed in response to high e

water temperature, as designed.

Even though the RWCU system was designed with high water temperature as a non-protective (non-EST) process parameter to prevent l

damage to the resin beds from high temperature, this event is reportable as an ESF actuation.'

An RWCU primary containment isciati:n (ESF actuati:n) occurred en pressurizati:n b2tveen :na RNCU sucti:n De requirernen (Or Janunued reportabia:y 0; [0ese () pes ui iiSF actuauonS are being reconsidered separately under rulemaking, 87 Orsi; ::UREC-1022, Fev. i

containment isolation valves during the restoration of the RWCU system after a maintenance outage.

An ENS notification and LER are required because a valid EST signal initiated the RWCU isolation and the actuation was not part of a planned procedure.

5 I

t l

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l l

l 4

Draft _tiUREG-1022, Rev. 1 86.

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p~

W tound inoperabic; therefore, the licensee dociared the HPCI system inoperable.

The plant entered a technical specification requiring that the automatic depressurization, low-pressure coolant injection, core spray, and isola *. ion condenser systems ren.ain operable during the 7-day LCO or the plant had to be shut down.

The licenseo made an ENS g

notification within 28 minutes and a follovup call after the s.nplifier on the HPCI flow transmitter was f1xed and the HPCI returned to operability.

g This single failure of the single train BWR system is repot table under $50.72 (b) (2) (iii) (B and D) and $50.73 (a) (2) (v) (B and D) because the system was unable to perform its safety function to rr. move residual heat or mitigate the consequences of an acci6ent.

It is reportable despite other systems being available that could have performed the safety function.

The timeliness of reporting was appropriate.

(3)

Single railure Prevents Radioactive Release Control in Non-Safety-Related System During a liquid radwaste release, a discharge monitor alarmed, sending a signal to close the discharge valvo.

The valve closed and reopened without the operators being aware of it.

The operators manually shut the valve to secure the release 5 minutes later.

The tank was resampled and was g

found to still be within limits.

The licensee made an ENS notification 24 hours lator.

No physical problems were found with the monitor or valve.

The alarm w'as attributed to high background radiation level in the monitor area.

A caution was added to an abnormal operating procedure warning that the valve will reopen after being reset, if the monitor alarm condition cleared.

The licensee submitted an._LER g

within 30, days - - g ( Q g 37DgQ'{$pj)g

/In ENS notification Idh[b b e ai$ei he SE r

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valve to remain closed demonstrated a condition for an ** i5h-(

ancontrolled release of radioactive materials.

This_is, h

reportable even though the system is not safety related

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beca_use it_p67fi ss_thiellaTety_funcQ i U F 6o~ntV6H Td f r a d_i o a ct i v e_ma t e r:i a l s_rg 1 e a s ep,.

However, the ENS notification should have been made within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of J discovery.

T Q LER J required 4 g%3 g

l (4)

PotTniial Common-Mode Failure dwet, 7vodidcd by Wup59 IN2_

upp\\wsc a 1, cmedy '7.13. b.

h Unit I was at full power when it was' determined that a 4

rupture of the house heating steam system piping located in the switchgear and the mechanical equipment rooms could create a harsh environment for safety-related equipment in those areas.

The licensee removed the house heating system from service the day this problem-Vas found. -Eleven-days

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input error inhibit switch was immediately returned to the I

normal position and a caution was added to appropriato plant instructions.

This event i s reportable under 550.72(b)(2) (iii) (A) and 5 50.7 3 (a) (2) (v) because the actions could have prevented fulfillment of the safoty function to shutdown the reactor.

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10 CTR 50.72 ggd (No corresponding Part 50.72 Licensees shall're rt:

"Any M*N"d requir-sment.)

event where a single cause or

f condition caused at least one independent train or channel 50 7 3(c )

to become inoperable in multiple systems or two N gt g :

independent trains or channels

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p to become inoperable in a gII p

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(A)

Shut down the reactor and

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maintain it in a safe shutdown

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conditionf

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(B)

Remove residual heat; (C) control the release of radioactive material; or (D)

Mitigate the consequences of an accident."

Although no ENS notification is specifically required for this type of event, it is probable that such an event could place the plant in en unanalyzed conditiohT outliTdelhPdesign-basis,__or in aconditionsnot-covered-by'theplant'soperatingoremer,gency

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procedures, in which dase 550.72 (b),(1) (ii), (b) (2 ) (1), or b

2 iii) would apply.

(c(om)m(on)-(modefailure-as-an',LERwithin30 days. Licensees are~req

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(.b12_XLC )i5 M mCSk Discussion i do4Wd h 5 o.736t)(2 / t ic The intent of this part of )tho-r)ule is to collect information on

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common-mode or common-cause failures that caused multiple-independent safety system trains or channels to become inoperable.

(Operability is defined in Section 3.3.3.)

Included in the commen-mode failures are malfunctions caused by such factors as high anbient temperaturr.s, heatup frc: energi:stien inahquate prv.mntive mainton :3, oil con aminati:r of air systems, incorrect lubrication, or use of nonqualified ccaponents.

Failures reported under this part of the rule should be actual failures. not potential enes.

rPotential corren-rode failures ma! ;e aparta O

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Draft NUREG-1022, Rev. 1 98

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release of radioactively contaminated tools or equipment to public areas a

non-routine relehras of radicactive effluents inadvertent public notification system operation or e

inoperability a

events previou sly caported under other $30.72 criteria Licensees generally do not have to report media and government interactions unless they are,reht~ed to, or' perceived-by-the public to ba related'Eo,'the radiological health and safety of_._

the public, onsite personnel, or protection of the environment.

For~ example [the NRC does np1 generally need to be informed under

-this critorion of:

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administrative matters e

(yq)h cwQe, Wi k (r ud e,

- NRC reactor operator licensee testing

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- licensee management changes Wo4-M M6 vs 's F

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- systematic assessment of licensee performance (SALP)

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ratings

- civil penalties

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- normal plant startnps, shutdowns, or maintenance O/dl VM N

- transportation of non-contaminated injured pqrsonnel

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- responses to media inquiries

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l minor deviations from sewage or chlorine ek b n't mNs routine re minor non ports of effluent releases to other agencies Mc M -

radioactive, onsite chemical spills l

minor incidents involving endangered specie., problem

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peacet01 strikes or civil demonstrations hting

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(Thi ~s criterion 0mphasizes notifying the NRC7 n a ^timel _y m_.___

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such events or s1*.uations.

Generally, the 4-hour ENS ann'eraf-notific tion clock starts at the time of the event, regardless of when other government agencies are notified or when the-press release is issued.

plant procedures.

Usually, such notifications are required by 1

When a press release or government notification is not required by plant procedures, the ENS notification clock starts at the time of the decision to plan the press release or make the gcVernment notification.

release or covernment nctification "is planncd"The criterion's wording that a pres

"' dill be 22d2' implies early notification to the NRC rather than aft 2r the I;;;-

Press Release The NRC has an oblicatie-

_o inter-

_he r;bli:

, b r; t acu:

witnin One NRC's purview that affect or iais6 public health and safety and to correct a concern about the significant n :::a:2:::::na.

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109 Draft NUREG-1022, Rev. 1

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information in a timely manner regarding such situations.

The NRC should be aware of information that is available for the press or other government agencies.

Licensees are encouraged to fax _a copy of the press release to the NRC operations Center and to inform the NRC resident inspector and the NRC region public affairs officer.

However, the NRC need not be-notified of every press release a licensee issues.

The field of NRC interest is narrowed by the phrase "related to the health and safety of the public or onsite personnel, or protection of the environment," in order to exclude administrative matters or those events without real or perceived 1

safety significance.

If a particular effluent release has safety significance or is expected to generate public, media, or other attention as a result of being unusual or abnormal, then it is reportable under this criterion.

Planned or low-level radiation releases are not specifically reportable under this criterion.

However, if a release receives media attention, the release can no longer be considered routine and the situation is reportable under this criterion.

If possible,-licensees should-make an ENS notification before issuing a press release because news media representatives will j

usually contact the NRC public affairs officer shortly after its issuance for verification, explanation, or interpretation of_the facts.

It is advantageous to the licensee, NRC, and news media, to provide tne NRC staff-with the time to consider the subject of the press release before any inquiry is received so the NRC can better address the public's concern.

Other Government Notifications For reporting purposes, "other_ government agencies" refersito local, State or other Federal agencies.

'Because other government agencies-often rely on the NRC for an independent: explanation of the safety: implications of events at nuclear power plants,.the NRC needs to be cognizant of reportable events in a timely-manner.

Notifying another Federal-agency does not relieve the licensee of the requiremont te repcrt to the NRC, Most Federal agencies notified by the licensee do not centact the NRC Operati ns Cantar.

Ihe Oepartment of Transpcrna:icn 2_Manicnal-Res; nse

. Center informs the NRC Operations Center of the licensee's-notification by procedure.

Routine reports to a local, State, or' Federal agency.that do not convey a perceived threat to the plant, environment, or public ac t a ti 92ed n:

be raper:2d

-h3 N7C 2rdar :n; Ort:tra n Draft NUREG-1022, Rev

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h An ENS notification is required within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> under this criterion because of-the notification of the State agency of the inadvertent radiological contamination of plant personnel.

This and cany other events reportable undar this criterion also are reportable under more limiting reporting criteria.

In this case, an ENS notification is required within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> under 550.72(b) (1)(vi) and an LER is required under both 550.73(a)(2)(x) and $50.73 (a) (2) (v).

(8)

State Notification of Improper Dumping of Radioactive Waste The licensee transported two secondary side filters to the city dump as nonradioactive. waste but later determined they were radioactive.

The dump site was closed and the filters retrieved.

The licensee notified the-appropriate State agency and the NRC resident inspector.

An ENS notification is required because of the-notification to the State agency of the-improper transport of radioactive material off site, which affects the radiological health and safety of the public and environment.

(9)

Non-Routine State Environmental Notification The licensee notified its State environmental protection agency and the NR? resident inspector of a fish kill i

involving 51 species in the circulating water discharge canal, possibly resulting from thermal water conditions.

An ENS notification is required because of the: notification-of a State agency of a significant fish kill, which the media or public could perceive as related-to an.cffsite radiological hazardLto the healthiand. safety-of the environment-and public.

(10) Routine Reports Regardingl Endangered Species The licensee notified the. National Fish:& Wildlife agency and a State agency that an endangered species ofysea-turtle was found in their circulating: water structure trash bar.

No press release was issued.

An ENS notification-is not required under this criterion.

Routine environmental _ reports to' State _and Federal.agencias are-belov the threshold of reperting under thi: criterien (11) Non-Routine Environmental Protection Agency' Notification Aflicensee found a' tear in their evarcrant'm thed that v3?

releasing _nycrazene to the environment.

-The licensee was not authorized by the U.S. Environmental Pr tection A0ency 113' Draft.NUREG-1022, Rev. 1

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(EPA) to release any hydrazene.

The licensee notified the EPA, several State agencies, and the county.

An ENS notification is required because notifications were cade to five government agencies regarding significant toxic releases related to the health and safety of the public.

(12) Routine Federal Agency Notifications A licensee notified the EPA that the circulation water temperature rise exceeded the release permit allowable.

This event was caused by the unexpected loss of a circulating water pump while operating at 92-percent power.

The licensee reduced power to 73 percent so_that the circulating water temperature would decrease to within the allowable-limits unti-1-the-pump coulWbaJapaired s

A licensee r.otified the Federal Aviation Agency that it removed part of its auxiliary boiler stack aviation. lighting f

". rom service tc replace a faulty relay.

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-A licensee notified the State, EPA, U.S. Coast Guard and Department of-Transportation that 5 gallons of diesel-fuel oil had spilled onto gravel-covered ground inside the protected area. The spill was cleaned up by_ removing the gravel'and dirt.

Although an ENS notification is-not-required on-su.ch-typical fro'utine notificatfons toMher Federal agencies because these events"do not pertain to the radiological health and safety of the public or the protection of the environment, licensees-are encouraged to inform their NRC resident inspectors.

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