ML20128B639
| ML20128B639 | |
| Person / Time | |
|---|---|
| Issue date: | 12/24/1991 |
| From: | Jordan E NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Lieberman J, Malsch M, Norry P NRC OFFICE OF ADMINISTRATION (ADM), NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML19341G314 | List: |
| References | |
| FRN-57FR28642, RULE-PR-50 AD03-1-012, AD3-1-12, NUDOCS 9302030119 | |
| Download: ML20128B639 (36) | |
Text
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9' UNITED STATES 1
NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D. C,20555
' ti rl December 24, 1991
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MEMORANDUM FOR:
Martin G. Malsch, Deputy General Counsel for Licensing and Regulation Patricia G. Norry, Director Office of Administration James Lieberman, Director Office of Enforcement i
FROM:
Edward L. Jordan, Director Office for Analysis and Evaluation of Operational Data i
SUBJECT:
PROPOSED MINOR RULEMAKING TO MODIFY OPERATING POWER REACTOR EVENT REPORTING REQUIREMENTS -
10 CFR 50.72 AND 50.73 Enclosed for your concurrence is a Negative Consent paper for the Commission (containing a Notice for Proposed Rulemaking to be published in the Federal Reaister and a draft Regulatory Analysis) concerning proposed minor changes to 10 CFR 50 72, "Immediate Notification Requirements for Operating Nuclect Power Reactors" ano 10 CFR 50.73, " License Event Report System." Our goal is to make the new rules effective as soon as practical. Due to the expedited schedule for this rulemaking, your concurrence is requested by COB January 10, 1992.
Based on the staff's review and analysis of both the reactor operating experience over the past seven years, and the comments received during the 1990 Event Reporting Workshops, we are proposing changes to 10 CFR 50.72(b)(2)(ii) and 50.73(a)(2)(iv).
Specifically, we are proposing to delete-current reporting requirements primarily for invalid actuations of certain engineered safety features.
Review of a limited set of specifically defined ESF actuations (e.g., reactor water cleanup. systems at BWRs and control room emergency ventilation systems) over a period of several hundred reactor-years of operation has identified no safety concerns and has provided little useful information upon which to assess plant performance.
On November 8,1991, the EDO approved staff's initiating rulemaking activities to amend the current operating reactor event reporting requirements.
In its review, the staff has determined that a backfit analysis is not required for this proposed rule.
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..p l I LMultiple Addressees- ;
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- This.. package has'been coordinated with staff members within
- your respective' offices.
If you have.any:' questions, the AE00- staff, contacts-:are:L Raji-M Tripathi--(x24435): for-50.73 and-Eric Weiss = (x29005): for-50.72.--
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Enclosure:
As stated
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L. Spessard V. Benaroya P. Baranowsky J. Rosenthal G. Zech J._ Crooks E. Weiss T. Murley, NRR C. Rossi, NRR R. Woodruff, NRR W. Russell, NRR S. Varga..NRR D. Crutchfield, NRR J. Richardson, NRR A. Thadant, NRR B. Grimes, NRR F. Congel, NRR J. Roe, NRR W. Reckley, NRR S. Long, NRR E. Beckjord, RES C. Heltemes, RES W. Morris, RES H. Fleishman, RES S. Treby, OGC G. Mizuno, OGC H. Taylor, OE00 J. W. Bateman, OEDO w/ enclosure:
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M. Fleishinan, RES AEOD 91-149 (WITS 91-00251)
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-Pledecisky Eqti The Commissioners p*
From:
James-M. Taylor, Executive Director for Operations:
Subject:
PROPOSED MINOR RULEMAKING TO MODIFY OPERATING POWER REACTOR EVENT REPORTING REQUIREMENTS--'10 CFR 50.72 AND 10 CFR 50.73 q<
Purpose:
To obtain Commission approval for publication;of a. Federal Reaister notice of proposed rulemaking.
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Backaround:
The staff's reactor operating experience' review over the-past 7 years-has shown that some event notifications and written reports are unnecessary.
In addition,.there ista _
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disparity and ~ diversity-among the licensees:in-understanding; the-intent of the existing event-reporting rules and, therefore, in-their applications. LThe' NRC Regulatory Impacti
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Study:(DraftNUREG-1395)-indicatedaneedforclarification-of the intent ~of the rules ~and for. additional guidance;on event reporting.-
In the Fall of 1990, in four workshops on event: reporting,
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organized'by AE00, NRR and NMSS, the staff interacted with:
licensees and industry-supported organizat;ons to obtain-feedback on their: experience with event reporting under the existing' rules.
Subsequently, a task group (AE00? NRR,-OGC,-
ADM) was! organized to provide-clarification-of the intent of.
Contact:
Raji-Tripathi,AE00 (301)-492-4435 l-Eric Weiss, AE00 (301)-492-9005 i
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%WonalI Lthe current rules-to improve the uniformity and_ completeness -
cof operating reactor event reporting..
In September 1991, AEOD issued for comment-a draft NUREGi i
1022, Rev.1, " Event Reporting SystemsL10 CFR.50.72 and 50.73
-- Clarification of NRC Systems and Guidelines For Report--
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-i ing," which contains-improved guidance for' event reporting,_
compiled by the task group. The staff's continuing. _.
examination of the reported events during development of-this document indicated that certain types of-invalid engineered safety feature (ESF) actuations' are not.-
important to safety, and any resources expended in reporting these events could be better spent in other safety-related r
(1)
Actuation -- Actuation of a component of an. engineered safety feature (ESF) or reactor protection system (RPS) is defined as either:
Receipt of'a signal (s) he protection channels' coincidence in the plant's protection _ system (a) sufficient to satisfy t 4
logic necessary to activate the ESF or the RPS-(system or--
component), independent of whether or not the_ ESF, or.the RPS,-or the component. operates; or-J1 (b) deliberate or inadvertent action (s) (manual or automatic) or Q
plant conditica(s) that activates;the:ESF or the.RPS (system / component),without-theprotection, channel'_
coincidence logic being satisfied (e.g., manual actuation of:
a a safety injection pump, an' electrical jumper being used to-L start an emergency diesel generator, or set-point drift y
. causing a boiling water _ reactor main steam safety / relief valve to open).
(2)
Valid ESF or RPS actuations are those that are:-
(a) 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 signals-to the: protection system's logic (whether or not the ESF/RPS-functions properly or a need ~ exists); or.-
(b) - manually initiated in response to plant _ conditions.-
(3)
Invalid actuations are other than those that are considered to'be-
" valid" as defined above.. Examples of:such events include those initiated by spurious voltage -spikes,- inadvertent manual actions (e.g., bumping cabinets, misplaced-jumpers, actuating wrong switches), equipment failures, or radio frequency' interference.
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f activities. - However, the staff could not expand the scoper O
- of the guidance document to include modifications to the '
. existing reporting requirements. Neither was -it possible to.
incorporate this document, by reference, in amending the- -
oxisting rules. Consequently,_the staff was advised by OGC_
to keep the:two issues. separate ---let the guidance document;-
clarify the intent of the existing rules, but initiate-a separate rulemaking activity-to modify the. current reporting requirements to relax the reporting of selected types of _ ESF actuations.
l The ACRS and CRGR_have deferred the review of this rulemaking until comment resolution; i.e. the final' rulemaking stage.
Discussion: contains the proposed rule' to make minor modifications to the existing reactor event reporting requirements. The proposed rule would have' minimal impact on the NRC's ability to fulfil its safety mission because-relaxation applies to specified events-which pose little or no safety concerns.
The resulting reductions in the industry and the NRC resources would also be consistent with 1
- the objectives and the requirements of the Paperwork-1
'F Reduction Act.
The following are the points considered in the proposed-p amendments to the-existing; regulation -
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In10CFR50.72(b)(2)(ii)and50.73-(a)(2)(iv),the existing rules require reporting of an event or condition-that results in a manual or automatic _ actuation of an engineered safety feature (ESF),--including:the reactor.
protection system (RPS), except wher, the actuation resulted from or.was part of a pre-planned sequence during testing or reactor operation. A pre-planned sequence implies that the piocedural step-indicates the speci.fic ESF 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/RPS actuates during the. planned operation or test in a way that; is not ) art of the planned procedure, such as at the wrong -
step, tie event is reportable.
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Based on reviews that indicated the frequencies of_such o
occurrences at the' majority of the plants is-low, the staff.
proposes to make add _itional relaxations _to event reporting.
as follows:
(1)
The first-category excludes events'_in which an invalid' ESF/RPS actuation occurs _ when the system.is already l
properly removed from service if all requirements of
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plant procedures for removing equipment from service-3 e
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'hivebeanmet. This would include required clearance documentation, equipment' and control board tagging, and arope-ly positioned valvesLand power supplyc brea(ers.
a (2)
The second category excludes eventssin which an
_ invalid ESF/RPS actuation occurs after..the safety function has already been completed. (e.g., an. invalid actuation of the RPS when all rods are fully-inserted, or an invalid containment isolation signal.whilm.the-containment isolation valves were already. closed).
.l (3)
The third category excludes events in:which an invalid ESF actuation occurs that involves only a limited set'
-of ESF systems, subsystems, or components (i.e.,.when an invalid actuation, isolation, or ~ re-alignment of.
only the reactor water clean-up (RWCU) system, or any of the following four ventilation systems: control:
3 room emergency ventilation (CREV). system, reactor-building ventilation system, fuel building ventilation.
s system, auxiliary building. ventilation system, or.
their equivalent ventilation systems occurs)._ Invalid actuations that involve other ESFs (such-as emergency core cooling system isolations or actuations;-
containment isolation valve closures.that--affect cooling systems, main steam flow, essential support-systems, etc.; containment spray actuation; and,-
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residual heat removals system isolations), not specifically excluded would continue to be reportable.
(4)
The fourth category excludes events that involve-actuations of ESF components (which have both-
.F protective (ESF).and non-protective (non-ESF)_
actuation circuitry] and the actuation results from a signal originating in the non-ESF circuitry.
For-instance, in a boiling water reactor, if an RWCU-system isolation. occurs because of a high pressure signal, the incidentLis reportable because the signal:
originated from the protective?(ESF) circuitry.
However, the event'is not reportable if the RWCU isolation occurs because of a high temperature signal originating in_the non-ESF circuitry. Although-the.-
same system components respond in both instances, in-the latter case the triggering mechanism was intended.
only to protect the-RWCU system resins from damage.
However, the staff remains interested in unplanned:
A reactor shutdowns originating from'_any source (i.e.,-
from the RPS as well as other anticipatory or non-RPS.
signals). 'Such events continue to be reportable. -
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Licensees.would continue to be required to submit LERs;if a L
deficiency or condition' associated with any'of the_ invalid-L 4
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hededsfonal ESF actuations of the RWCU or the CREV systems,- or reactor building ventilation system, fuel building ventilation system, auxiliary building ventilation system.(or other equivalent ventilation systems) satisfies any reportability-criteria under 950.72 and 650.73.
Resources:
We estimate the resource commitment of 1.0 staff-year for AE00 and 0.5 staff-year for other NRC offices to prepare, review and approve the rule changes. The proposed rule changes are expected to result in about a 5-10 percent re-duction in the number of LERs, i.e., about 150 LERs each year.
Similar savings are estimated in the 50.72 notifica-tions.
The incremental cost reduction to industry is about $2600-per event for both 50.72 and 50.73 reports.
For the NRC, the reduction in processing cost from a 5 to 10 percent reduction in 50.72 notifications would be negligible, be-cause the entire duty officer staff would remain the same, and the screening of these relatively unimportant events by -
NRR would not affect the total event screening effort significantly. There would, however, be cost savings for NRC as a result of a reduction in LER screening, coding and processing.
The incremental cost reduction to the NRC is estimated to be about $2400 per LER.
Recommendation:
Unless the staff is instructed to the contrary within 10 days from the date of this paper, the enclosed amendments to 10 CFR 50.72 and 50.73 will be issued as a proposed rule.
Coordination:
The Office of General Counsel has no legal objection.
James H. Taylor, Executive Director for Operations
Enclosures:
- 1. Federal Reaister Notice
- 2. Draft Regulatory Analysis
- 3. Congressional Letters i
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ENCLOSURE 1
[1 Predocisional L
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7590-01 NVCLEAR REGULATORY COMMISSION 10 CFR PART 50 i
RIN 3150-AE12 Minor Modifications to the Nuclear Power Reactor Event Reporting Requirements AGENCY:
Nuclear Regulatory Commission.
ACTION:
Proposed rule,
SUMMARY
The Nuclear Regulatory Commission (NRC) proposes to amend its regulations to make minor modifications to the current nuclear power reactor event reporting reautrements. Tha proposed changes would apply to all nuclear power reactor licensees and would delete reporting requirements for some events that have been determined to be of little or no safety significance.
This rule change will reduce the industry's reporting burden and the NRC's I
response burden in event review and assessment.
DATE: The comment period expires (75 days following publication in the Federal Reaister).
Comments received after this date will be considered if it is practical to do so, but the Commission is able to assure consideration only for comments received on or before this date.
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Predocktonal s
ADDRESSES: Hall written comments to: U.S. Nuclear Reguintory Commission, Vashington, DC 20555, ATIN: Docketing and Service Branch.
Deliver comments to One White Flint North, 11555 Rockville Pike, Rockville, MD, between 7:30 am and 4:15 pm on federal workdays.
Commenters are encouraged to submit, in addition to the original paper copy, a copy of their comments in an electronic format on IBM PC 005 compati-i ble 3.5 or 5.25 inch, double sided diskettes. Data files should be provided in Wordperfect 5.0, or 5.1.
ASCll code is also acceptable, or if formatted text is required data files should be submitted in IBM Revitable format Text
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Document Content Aichttecture (RFT/DCA) format.
Copies of the environmen',a1 assessment, the draf t regulatory analysis, l
the finding of no significant irnpact, the supporting statement submitted to I
OMB, and comments received may be examined at: The NRC Public Docuinent Room, 2120 L Street NW. (Lower level), Washington DC.
I FOR FURTHER 1HFORM>,,10N CONTACT:
Raji Tripathi (10 CFR 50.73) or Eric Weiss (10 CFR 50.72), Office for Analysis and Evaluation of Operational Data, U.S.
Nuclear Regulatory Commission, Washington DC 20555. Telephone (301) 492 4435 and 492-9F 5 respectively.
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Pledoctional 5UPPLEMENTARY INFORMATION:
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BACKGROUND The Commission is proposing minor changes to the current nuclear power reactor event reporting requirements contained in 10 CFR 50.72, 'Immediate Notification Requirements for Operating Nuclear Power Reactors " and 10 CFR 50.73, " Licensee Event Reporting System,* as part of on going activities to improve its regulations.
In this regard, various reviews by the NRC staff of operating experience and the patterns of licensees' reporting of operating events since 1984 have indicated that the reporting of certain types of events are not contributing
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useful information to the operating database, and is no longer necessary.
Such unnecessary reporting is consuming resources in preparation and review that would be better applied cisewhere.
Over the past several years, the NRC staff has increased its attention to event reporting i* sues to ensure uniformity, consistency, and completeness in event reporting. As a result, in September 1991, the NRC's Office for Analysis and Evaluation of Operational Data (AE00) issued for comment a draf t NUREG-1022 Revision 1,' " Event Reporting Systems 10 CFR 50.72 and 50.73 --
Cisrification of NRC Systems and Guidelines for Reporting," which contained improved guidance for event reporting. The NRC staff's continuing examination A free single f.opy may be requested by writing to the Distribution and Mail Services Section, U.S. Nuclear Regulatory Commission, Washington DC 20555.
A copy is also available for inspection or copying for a fee at the NRC Public Document Room, 2120 L Street, NW (Lower Level), Washington, DC.
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of the reported events during development of this document indicated that certain types of invalid engineered safety feature (EST) actuations' are not 4
important to safety, and any resources expended in reporting these events could be better spent in other safety related activities, in addition, the staff determined that for the same reasons ESF equipment actuations need no longer be reported if the actuations occurred from non EST signals.
Based on the NRC's evaluation of both the reported events since January t
(1)
Actuation - Actuation of a component of an engineered safety feature (EST) or reactor protection system (RPS) is defined as eithert (a)
Receipt of a signal (s) in the plant's protection system sufficient to satisfy the protection channels' coincidence logic necessary to activate the ESF or the RPS (system or component), independent of whether or not the ESF, or the RPS, or the component operates; or (b)
Deliberate or inadvertent action (s) (manual or automatic) or plant
,t condition (s) that activate the ESF or the RPS (systern/ component),
I without the protection channel coincidence logic being satisfied (e.g., manual actuation of a safety injection pump, an electrical i
jumper being used to start an emergency diesel generator, or set-point drift causing a boiling water reactor main steam safety / relief valve to open).
(2)
Valid ESF or RPS actuations are those that are:
(a)
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 signals to the protection system's logic (whether or not the ESF/RPS functions properly or a need exists); or (b)_ Manually initiated in response to plant conditions.
(3)
Invalid actuations are other than those that are considered to be-
' valid" as defined above. Examples of such events include those initiated by spurious vcitage spikes, inadvertent manual actions (e.g.,
bumping cabinets, misplaced jumpers, actuating wrong switches),
equipment failures, or-radio frequency interference.
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i 1984, when the existing rules first became effective, and the comments received during the Event Reporting Workshops in Fall 1990, some needed improvements in the rules were identified.
For instance, it was determined that some events only involving invalid ESF actuations are of little or no j
safety significance but are currently reportable pursuant to 10 CFR 50.72
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(b)(2)(ii)and50.73(a)(2)(iv).
Events in this category are invalid actua-tions of, for instance, the reactor water clean-up (RWCU) system and the control room emergency ventilation (CREV) system, which actuate various system components, but pose no safety concerns.
The original Statements of Consideration for the current event reporting regulations, 10 CFR 50.72 and 50.73 (Federal Reatster, Vol. 48, NO.
168, Honday, August 29, 1983, and No. 144. Tuesday, July 26, 1983, respectively), indicated that ESF systems, including the reactor protection system (RPS), are provided to mitigate the consequences of a significant event. Therefore, ESFs should (1) work properly when called upon and (2) should not be challenged frequently or unnecessarily. The Statements of Consideration also indicated that operation of an ESF as part of a pre planned operational procedure or test need not be reported. The Commission also noted that ESF actuations, including reactor trips, are frequently associated with significant plant transients and are indicative of events that are of safety significance. At that time, the Commission also required all ESF actuations, including the RPS actuations -- mcnual or automatic, valid or invalid --
except as noted, to be reported to the NRC by telephone within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of occurrence followed by a written Licensee Event Report (LER) within 30 days of the incident. This requirement on timeliness of reporting remains unchanged.
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The reported information is used by the NRC in confirmation of the licensing bases, identification of precursors to severe core damage, reviews of management control systems, performance indication, and the identification of actions to minimize unnecessary actuations of safety systems.
DISCUSSION i
Relaxing reporting requirements for certain ESF actuations, primarily l
invalid actuations, could save resources for both the industry and the NRC.
The Commission emphasizes that not all invalid ESF actuations would be relaxed from reporting. The relaxations in event reporting requirements as contained in the proposed rule would apply only to a limited set of specifically defined invalid ESF actuations.
Such events, for example, would include invalid actuation, isolation, or re-alignment of a limited set of ESFs or their equivalentsystems, subsystems,orcomponents(i.e.,whenaninvalid actuation, isolation, or re-alignment of only the RWCU system, or the CREV system, reactor building ventilation system, fuel building ventilation system, or auxiliary building ventilation system). Such actuation / isolation /re-alignment events are of minimal safety significance because they result in the system being in a safe condition, and contribute little to operating experience data, llowever, invalid actuations of other ESFs such as emergency core cooling system isolations/actuations; containment isolation valve closures that affect cooling systems, main steam flow, essential support systems, etc.; containment spray actuation; and, residual heat removal system isolations would continue to be reportable.
In the proposed rule, in addition-to the-specified invalid ESF actuations, some other ESF actuations would.be 6
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excluded.
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The Commission, however, considers it prudent to emphasize that if an invalid l
i ESF actuation-reveals a defect in the system such that it failed or would fail 1
to perform its intended function, the event continues to be reportable under other requirements of 10 CFR 50.72 and 50.73. To be specific, if'a condition f
or deficiency has (1) an adverse impact on safety-related equipment and conse-quently on the ability to shut down the reactor and maintain it in a safe shutdown condition, or (2) has a potential for significant radiological release or potential exposure to plant peg!. int; :* the general public, or (3) would compromise control room habitabilio, lo event / discovery continues to be reportable.
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Invalid ESF actuations that are excluded by this rule change, but occur as a part of a reportable event -should continue to be described as part of the reportable event.
Nothing here should be interpreted as precluding submittal of a complete, accurate and thorough description of an event'when it is reportable under the reporting requirements of 10 CFR 50.72 or 10 CFR 50.73. The Commission is proposing to relax only the selected event reporting requirements. Any anomalies that are excluded from reporting would.need.
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continued licensee attention under 10 CFR 50, Appendix B, " Quality' Assurance
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Criteria for Nuclear Power Plants and fuel Reprocessing Plants." For example, j
. based on the NRC's review of reactor operating experience, the potential exists for. increased occupational radiation exposures associated with the:
licensees' event investigation and recovery of the RWCU systems'following invalid isolations. Therefore, licensees must continue to take steps l
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1 Predocislonal necessary to minimize undue isolations of the RWCU systems and to reduce the potential for unnecessary occupational exposures. Also, invalid CREV isolations continue to need to be minimized so that the control room operators are not distracted from attending to events of greater urgency.
In 10 CFR 50.72 (b)(2)(ii) and 50.73 (a)(2)(iv), the existing rules requires reporting of an event or condition that results in a manual or automatic actuation of an ESF, including the RPS, except when the actuation results from or was part of the pre-planned sequence during testing or reactor operation. This implies that the procedural step indicates the specific ESF-or RPS actuation that will be generated, and control room personnel are aware l
of the specific signal generation before its occurrence or indication in the control room. However, if the ESF, including the RPS, actuates during the l
planned operation or test in a way that is not part of the planned procedure, such as at the wrong step, the event is reportable.
The Commission proposes to make additional relaxations to event reporting by excluding four additional categories of events as follows:
(1)
The first category excludes events in which an invalid ESF/RPS actuation occurs when the system is already properly removed from service if all requirements of plant procedures for removing equipment from service have been met. This would include required clearance documentation, equipment and control board tagging, and properly positioned valves and power supply breakers.
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ProMdonat 9
(2)
The second category excludes events in which an invalid ESF/RPS actuation occurs after the safety function has already been completed (e.g., an invalid actuation of the RPS when all rods are fully inserted, or an invalid containment isolation signal while the containment isolation valves were already closed).
(3)
The third category excludes events in which an invalid ESF actuation occurs that involves only a limited set of ESF systems, subsystems, or components (i.e., when an invalid actuation, isolation, or re elignment of only the reactor water clean-up (RWCU) system, or any of the following four ventilation systems: control room emergency ventilation 3
(CREV) system, reactor butiding ventilation system, fuel building venti-lation system, auxiliary butiding ventilation system, or their equivalent ventilation systems occurs).
Invalid actuations that involve other ESfs (such as emergency core cooling system isolations or actuations; containment isolation valve closures that affect cooling systems, main steam flow, essential support systems, etc.; containment spray actuation; and, residual heat removal system isolations), not specifically excluded would continue to be reportable.
(4)
The fourth category excludes events that involve actuations of ESF components (which have both protective (ESF) and non protective (non-ESF) actuation circuitry) and the actuation results from a signal originating in the non ESF circuitry.
For instance, in a bolling water reactor, if an RWCU system isolation occurs because of a high pressure signal, the incident is reportable because the signal originated from 9
.y Predocisional j
the protective (EST) circuitry.
Ilowever, the event is not reportable if 1,
the RWCU isolation occurs because of a high temperature signal originating in the non ESF circuitry. Although the same system components respond in both instances, in the latter case the triggering mechanism was intended only to protect the RWCU system resins from damage, flowever, the Commission remains interested in unplanned reactor shutdowns originating from any source (i.e., from the RPS as well as other anticipatory or non RPS signals).
Such events continue to be reportable.
Licensees would continue to be required to submit LERs if a deficiency or condition associated with any of the invalid ESF actuations of the RWCU or the CREV systems (or other equivalent ventilation systems) satisfies any reportability criteria under $50.72 and 650.73.
Impact Relaxing the current requirement for reporting of certain types of ESF actuations will reduce the industry's-reporting burden and the NRC's response burden.
This reduction would be consistent with the objectives and the requirements of the Paperwork Reduction Act. The proposed rule changes will have minimal impact on the NRC's ability to fulfil its mission to ensure public health and safety because the reporting requirements that the Commission proposes to delete have little or no safety significance.
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Predecisiong l
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It is estimated that the proposed changes to the existing rules will result in about 150 (or 510 percent) fewer Licensee Event Reports each year.
Similar reductions are expected in the number of prompt event notifications reportable under 10 CfR 50.72.
The licensees are encouraged to submit their estimates on impact of the 1
proposed rule change as comments.
finding of No Significant Environmental Impact: Availability i
The Commission has determined under the National Environmental Policy l
Act of 1969, as amended, and the Commission's regulations in Subpart A of 10 CFR Part $1, that this rule change, if adopted, would not be a major Federal action significantly affecting the quality of the human environment and, therefore, an environmental impact statement is not required. The proposed rule relaxes current reporting requirements for certain engineered safety feature actuations which, based on the NRC staff's review of several hundred reactor-years of operational experience have been determined to be of little or no safety significance. The environmental assessment and finding of no impact on which this determination is based are available for inspection at the NRC Public Document Room, 2120 L Street NW (Lower Level), Washington DC.
Single copies of the environmental assessment and finding of no significant impact, and the regulatory analysis are available from:
Raji Tripathi, Office for Analysis and Evaluation of Operational Data, U.S. Nuclear regulato-ry Commission, Washington, DC 20555, telephone: (301) 492 4435.
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t Paperwork Reduction Act Statement This proposed rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq). This rule has been submitted to the Office of Management and Budget for review and approval of the paperwork requirements.
Because the rule would relax existing reporting requirements, public reporting burden for the collection of information is expected to be reduced.
It is estimated that about 150 fewer Licensee Event Reports (NRC form 366) cod a similarly reduced number of prompt event notifications, made pursuant to 10 CFR 50.72, will be required each year. The resulting reduction in burden f
is estimated to average 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.
Send comments regarding the estimated burden reductions or any i
other aspect of this collection of information, including suggestions for further reducing reporting burden, to the Information and Records Management Branch (NMBB-7714), U.S. Nuclear Regulatory Commission, Washington, D.C.
20555; and to the Desk Officer, Office of Information and Regulatory Affairs, NE0B-3019, (3150-0011 and 3150 0104), Office of Management and_ Budget, Washington, D.C. 20503.
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Predecisional o
Regulatory Analysis i
lhe Commission has prepared a draft regulaf.ory analysis on this proposed rule change.
The analysis examines the costs and benefits of the alternatives l
considered by the Comission.
The draft analysis is available for inspection in the NRC Public Document Room, 2120 L Str9et NW. (Lower level), Washington DC. Single copies of the draft analysis may be; obtained from: Raji Tripathi, Office for Analysis and Evaluation of Operational Data, U.S. Nuclear Regulato-ry Commission, Washington DC 20555 Telephone (301) 492-4435.
Regulatory Flexibility Certification in accordance with the Regulatory Flexibility Act of 1980, (5 U.S.C. 605 (B)), the Commission certifies that this rule will not, if promulgated, have a significant economic impact on a substantial number of small entities. The proposed rule affects only the licensing and operation.of nuclear power pl ants. The companies that own these plants do not fall within the scope of the definition of "small entities" set forth in the Regulatory Flexibility Act or the Small Business Size Standards set out in regulations issued by the Small Business Administration Act in 13 CFR Part 121.
Backfit Analysis j
I As required by 10 CFR 50.109, the Commission has completed an assessment of the need for Backfit. Analysis for the proposed rules. The proposed i:
amendments include relaxations of certain existing requirements on reporting r
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bred & &
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of information to the NRC.
Changes in reporting requirements are not consideredbackfitsunder10CFR50.109(a)(1).
Therefore, the proposed rule does not require preparation of a Backfit Analysis.
List of Subjects in 10 CFR Part 50 Antitrust, Classified information, Criminal penalty, Fire prevention, Incorporation by reference, Intergovernmental relations, Nuclear power plants and reactors, Penalty, Radiation protection, Reactor siting criteria, Report-ing and record keeping.
For the reasons set out in the preamble and under the authority of the -
1 Atomic Energy Act of 1964, as amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the Commission is proposing to adopt the following amendments to 10 CFR Part 50.
PART 50 DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES 1.
AUTHORITY:
Sections 102, 103, 104, 105, 161, 182, 183, 186, 189, 68 Stat. 936, 937, 938, 948, 953, 954, 955, 956, as amended, sec. 234, 83 Stat.
1244, as amended (42 U.S.C. 2132, 2133, 2134, 2135, 2201, 2232, 2233, 2236, 2239, 2282); secs. 201, as amended, 202, 206, 88 Stat. 1242, as amended, 1244, 1246 (42 U.S. C. 5841, 5842, 5846).
Section 50.7 also issued under Pub. L.95-601, sec.10, 92 Stat. 2951-(42 U.S.C. 5851).
Section 50.10 also issued under secs. 101, 185, 68 Stat.
936, 955, as amended (42 U.S.C. 2131, 2235); sec. 102, Pub. L.91-190, 83 14
e kredecisional Stat. 853 (42 U.S.C. 4332). Sections 50.13, and 50.54(dd), and 50.103 also issued under sec, luB, 68 Stat. 939, as amended (42 U.S.C. 2138).
Sections 50.23, 50.35, 50.55, and 50.56 also issued under sec.185, 68 Stat. 955 (42 U.S.C. 2235).
Sections 50.33a, 50.55a and Appendix Q also issued under sec. 102, Pub. L.91-190, 83 Stat. 853 (42 U.S. C. 4332).
Sections 50.34 and 50.54 also issued under sec. 204, 88 Stat. 1245 (42 U.S. C. 5844).
Sections 50.58, 50.91, and 50.92 also issued under Pub. L.97-415, 96 Stat. 2073 (42 U.S.C.
2239).
Section 50.78 also issued under sec.122, 68 Stat. 939 (42 U.S.C.
2152).
Sections 50.80 - 50.81 also issued under sec.184, 68 Stat. 954, as amended (42 U.S.C. 2234). Appendix F also issued under sec.187, 68 Stat. 955 (42 U.S.C. 2237).
For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273);
Sections 50.5, 50.46(a) and (b), and 50.54(c) are issued under sec. 161b, 68 Stat.948,asamended(42U.S.C.2201(b)); Sections 50.5,50.7(a),50.10(a)-
(c), 50.34(a) and (e), 50.44(a)-(c), 50.46(a) and (b), 50.47(b), 50.48(a),
(c), (d), and (e), 50.49(a), 50.54(a), (i), (i)(1), (1)-(n), (p), (q), (t),
(v), and (y), 50.55(f), 50.55a(a), (c)-(e), (g), and (h), 50.59(c), 50.60(a),
50.62(b), 50.64(b), 50.65, and 50.80(a) and (b) are issued under sec. 1511, 68 Stat. 949, as amended (42 U.S.C. 2201(i)); and Sections 50.49(d), (h), and (j), 50.54(w), (z), (bb), (cc), and (dd), SG.55(e), 50.59a(b), 50.6)(b),
50.62(b), 50.70(a), 50.71(a)-(c) and (e), 50.72(a), 50.73(b), 50.61(b),
50.62(b), 50.70(a), 50.71(a)-(c) and (e), 50.72(a), 50.73(a) and (b), 50.74, 50.78, and 50.90 are issued under sec. 1610, 69 Stat. 950, as amended (42 U.S.C.2201(o)).
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I Predecisional i
j 2.
$50.72 Immediate Notification Reauirements for Operatina Nuclear Power Reactors (b)
Non cmergency events (2)
Four-hour reports i
1 (ii) Any event or condition that results in a manual or automatic actuation of an engineered safety feature (ESF), including the reactor protection system (RPS), except when:
(A)
The actuation results from or is part of a pre planned sequence during testing or reactor operation; (B)
The actuation is inclid and:
(1) occurs while the system is properly removed from service; or (2) occurs after the safety function has been already completed; or (3) involves only the following specific ESFs or their i
equivalent systems:
(a) reactor water clean-up system,-(b) control room emergency venti'.ation system, (c) reactor l
building ventilation system, (d) fuel building ventilation system, or (e) auxiliary building ventilation system; or 16
Predecisional 3...
'(C)
The actuation involves ESF (except the RPS) components and results from a signal that originated from non ESF (e.g., control) j
.i circuitry.
3.
$50.73 Licensee Event Reporting System l
i l
(a)
Reportable events.
4 (2)
The licensee shall report:
(iv) Any event or condition that resulted in a manual or automatic actuation of an engineered safety feature (ESF), including the; reactorprotectionsystem(RPS),exceptwhen:
(A).
The actuation resulted from or was part of a pre planned sequence-during testing or reactor' operation; (B)
The actuation was invalid and (1) occurred while the system was properly removed 'from service;-
or
-(2) occurred after the safety function had been already completed; or 17
Predecislonal
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g (3) involved only the following specific ESfs or their equivalent systemst (a)reactorwatercleanupsystem,(b) control room emergency ventilation system, (c) reactor building ventilation system, (d) fuel building ventilation system, or (e) auxiliary building ventilation systems or (C)
The actuation involved ESF (except the RPS) components and resulted from a signal thst originated from non-FSF (e.g.,
control) circuitry.
Dated at Rockville, MD, this day of
, 1992.
For the Nuclear Regulatory Commission.
James H. Taylor, Executive Director for Operations
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ENCLOSURE 2
Regulatory Analysis i
The NRC staff has prepared a draft regulatory analysis of this proposed i
rule change. The analysis examines the costs and benefits of the alternatives considered by the NRC.
The following is the draft analysis:
1.
Statement of the Problej The Nuc1 car Regulatory Commission (NRC) is proposing to amend its regulations on reporting of operating reactor events. Specifically, the affected regulations are 10 CFR 50.72, "Immediate Notification Requirements for Operating Nuclear Power Reactors", and 10 CFR 50.73, " Licensee Event Report System".
Currently, 10 CFR 50.72 and 50.73 require that NRC licensees for nuclear power i
reactors report any event or condition that involves actuation of any engineered safety feature (ESF, including the reactor protection system (RPS), except for actuations t at resulted from and were part of a preplanned sequence during testing or during reactor operation. The events are required to be reported via a telephone within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of discovery pursuant to 10 CFR 50.72(b)(2)(ii and within 30 days in a Licensee Event Report (LER)f the LERs in accordance wit 10 CFR 50.73(a)(2 (iv). Approximately 40 percent o (over 800) received annually invo ve ESF actuations; a similar number of telephonic event notifications are also made.
Based on the review of reactor operational experience since January 1, 1984, when the current 10 CFR 50.72 and 50.73 first became effective, the NRC staff has determined that the reporting of certain events of little or no safety significance constitutes a large number of reports.
Examples of events in this category include invalid actuations of certain ESFs, such as isolations of the reactor water cleanup system, actuations of the control room emergency ventilation system, and invalid RPS actuations when the all rods are fully inserted. The staff has concluded that reports on these events are not necessary for the NRC to perform its safety mission. Therefore, the-staff proposes to relax reporting of certain events of little or no safety significance, deferring to licensee oversight.
The proposed rulemaking action is consistent with and responsive to NRC findings from the Regulatory Impact Survey, NVREG-1395, " Industry Perceptions of the Impact of the U. S. Nuclear Regulatory Commission on Nuc1 car Power Plant Activities". Draft Report, March 1990.
2.
Ob.iectives The present reporting requirements of 10 CFR 50.72 and 50.73 require reporting of all ESF actuations, including the RPS system, except for actuations that resulted from and were part of a preplanned sequence during testing or during reactor operation.
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The proposed changes will climinate the reporting requirements on certain types of events that are now reportable and have been determined to be of l
little or no safety significance. This reiaxation will not hamper the NRC's l
ability to meet its mission to protect public health and safety.
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DRAFT I
3.
Alternatives No other reasonable alternatives were identified.
The only alternative to the proposed action is for the NRC to take no action at this time.
4.
Com1quences a.
Costs and Benefits of Alternatives The only reasonable alternative to the proposed action identified is to take no action; the incremental costs and benefits of that alternative are zero.
However, taking no action would result in continued reporting of events that are not needed for the NRC staff to fulfil its safety mission, and consequently unnecessarily consume both NRC and industry resources.
The principal benefit of the proposed amendments is a reduction in the efforts expended by both the NRC and the licensees on issues of little or no safety significance. This will free both NRC and licensee resources that col 1d be better spent on issues of greater importance.
Based on review of past
.R data, the proposed rule changes are expected to result in about 150 (or 5 to 10 1ercent of the total) fewer LERs.
The same reduction is expected in the i
num>er of immediate event notifications.
The cost of the proposed action consists of the cost of the rulemaking effort by NRC, and the potential costs of rewriting procedures and personnel training provided to the their staffs by the licensees. Cost savings for both the NRC and the industry are shown in Table 1 below. NRC costs were calculated in accordance with the guidance in NUREG/CR 3568, "A Handbook for Value-Impact Assessment," and general cost-benefit methodology.
It was assumed that industry expends 50 staff hours for each of these relatively simr.le LERs, and about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for each 50.72 notification.
At $48 per hour, the incremental cost to industry is therefore about $2600 for both reports. For NRC, the processing cost reduction due to a 5 to 10 percent reduction in 50.72 notifications would be negligible, because the entire duty officer system would remain the same, and the screening of these relatively unimportant events by NRR would not affect total event screening effort significantly. There would, however, be cost savings for NRC due to a reduction in LER processing, review and assessment. Assuming that NRC expends 50 staff-hnurs for evaluating each LER, at $48 per hour, the incremental cost to the NRC is therefore about $2400 per LER.
DRAFT Table 1.
Estimated Incremental Im)act Based on an Estimated Annual Reduction of 150.icensee Event Reports (9111 bJlILuJtl k
ar Present Worth Total Costs
[.0111 fjtdar. Based on a 5%
Over 30 Real Discount Rate Yeart Industrv Co.it ($2600
$390,000 15.4
$6,000,000 per report)
I NRC_[nti ($2400 per
$360,000 15.4
$5,500,000 report) i The proposed rulemaking could save both the NRC and industry over $350,000 a year, or over $5,500,000 each over the next 30 years (present worth: 5 percent discountrate). The cost of the rulemaking itself would require about 1.5 NRC i
staff years, reducing the cost savings by about $150,000 the first year.
In i
addition, the cost savings for NRC may be somewhat less, because the types of 5
LERs to be eliminated are ones for which review and assessment would be less than that for the average LER.
4 Assuming the cost of rewriting procedures is about $3300 per licensee, the result would be to subtract about $260,000 from the industry cost savings the first year. The cost of personnel training provided to their staff by the licensees is more difficult to determine. Since the rulemaking will decrease reporting requirements, it is hoped that training would be minimal and cost less than the first year's savings.
NOTE:(******** Estimates of reduction in the licensee burden will be solicited through the Federal Register Notice.**************"**)
b.
Impacts on Other Requirements Because the LERs and immediate notifications to be eliminated are of little or no saf ety significance, the action will not have any impacts on other NRC programs or requirements, licensee operations or other activities, c.
Constraints There are no known constraints (legal, institutional, scheduling, enforceability, or policy) on the industry or on the NRC for the proposed action.
5.
Decision Rationale The pro)osed changes will eliminate some existing reporting requirements.
There siould be a reduction of approximately 150 telephonic event notifications and LERs per year (about 5 to 10 percent of the yearly total),
due to the elimination of reporting of certain ESF actuations. The extent of the changes will vary from licensee to licensee. We expect that the total number of reports and the associated information that needs to be prepared by the licensees, and subsequently reviewed by the NRC, will decrease moderately.
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DRAFT I
6.
Implementation a.
Schedule for Implementing the Proposed Requirement The final rule is expected to be published ap3roximately nine months after
>ublication of the proposed rule, or about fe)ruary 1993. The new rule would
)ecomo effective one month later.
Regulatory guidance will be provided by the latest revision of NUREG-1022 and Guidelines for Reporting".[R 50.72 and 50.73, Clarification of NRC Systems
" Event Reporting Systems,10 C This NUREG will be revised to reflect completion of the rulemaking action 3ro>osed above, and the revised NVREG publication will be synchronized wit 1 tie final rulemaking changes to 10 CFR 50.72 and 50.73.
b.
Relationship to Other Existing or Proposed Requirements No effect on other NRC requirements is anticipated. The rulemaking will be coordinated with the issuance of a revision of NUREG-1022, as discussed above.
The rulemaking and guidance revision are complementary.
The NRC staff requests public comments on the draft analysis which may be submitted to the NRL as indicated under the ADDRESSES heading.
l t
' Copies of the latest revision of NUREG-1022 may be purchased from the Superintendent of Documents, U.S. Government Printing Office, P.O. Box 37082 Washington, D.C. 20013-7082. Copics are also available from the National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161. A copy is also available for inspection or copying for a fee at the NRC Public Document Room, 2120 L Street, NW. (Lower level), Washington, DC.
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ENCLOSURE 3 I
f
DRAFT D
l<
t The lionorable Bob Graham, Chairman Subcomittee on Nuclear Regulation y
Comittee on Environment and Public Works United States Senate-Washington, D.C.
20510
Dear Mr. Chairman:
The United States Nuclear Regulatory Comission (NRC).has sent to the Office of:
the Federal Register for publication the enclosed proposed amendment to the Comission's rules in 10 CFR Part 50. The amendment, if adoptedo would relax
- reporting (by telephone as well-as in written L.icensee Event Reports) of certain random, spurious events involving actuations of a limited set of specifically defined engineered safety features. These events have been determined to be of minimal safety significance.
Based on the Comission's review of such events over several-hundred. reactor-years of experience has provided-little useful information upon which to assess plant performance.
Relaxing reporting requirements on these events will save the industry, as well as the NRC resources-which could be expended on matters of greater urgency. The proposed rule will
- have minimal impact on the'NRC's ability to carry its missions to ensure public_
l health and safety.
The Comission is issuing the proposed rule for pubic comment-.and has specifically requested coments-with respect to assessment. on incremental ~
reduction in the licensees' resources.
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Sincerely, Dennis K. Rathbun, Director Office of Congressional Affairs
Enclosure:
As stated
=;
. cc; Senator Alan K. Simpson 4
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The Honorable Peter Kostmyer, Chairman Subcommittee on Energy and Environment DRAFT Committee on Interior and Nuclear Affair united States House of Representatives Washington, D. C.
20515
Dear Mr. Chairman:
The United States Nuclear R60slatory Comission (NRC) has sent to the Office f
of the federal Register for publication-the enclosed proposed amendment to the--
l' Comission's rules in 10 CFR Part 50. The amendment, if adopted would relax-reporting (by' telephone as well as in written Licensee-Event Reports) of-certain random, spurious events involving actuations of a limited-set of-specifically defined engineered safety features. These' events have ben c
determined to be-of minimal safety si nificance.
Based on the Commission's-
- 11' reiew of such events over several hu dred years of experience has provided littic useful information toon which to assess plant performance.
Rela:iing reporting req'irements on tiese events will save the industry, as well as'the' a
NRC resources which could be expended on matters of greater urgency. The-proposed rule will have no_ impact on the NRC's ability to carry its missions -
to ensure public health and safety.
The Commission is issuing the proposed rule for pubic comment' and has f
specifically requested comments with respect to assessment on incremental-reduction in the licensees' resources.
Sincerely, Dennis K. Rathbun, Director 3
Office of Congressional Affairs
Enclosure:
As stated cc: Representative John J. Rhodes f.
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-The. Honorable Philip R. Sharp, Chairman Subcomittee on Energy and Power Dah7 Comittee on Energy and Commerce FT United States House of Representatives Washington, D. C.
20515
Dear Mr. Chairman:
The United States Nuclear Regulatory Comission (NRC) has sent to the Office of the Federal Register for publication the enclosed proposed amendment to the -
Comission's rules in 10 CFR Part 50.
The amendment,1 f adopted Would relax reporting (by telephone as well as in written Licensee Event Reports) of certain random, spurious events. involving actuations of a limited set of specifically defined engineered safety features. These events have been determined to be of-minimal safety significance.
Based on the Comission's review of.such events -
over several hundred reactor-years of experience has provided little useful information upon which to assess plant performance.
Relaxing reporting requirements on these events will save the industry, as well as the NRC resources.
l which could.be expended on matters of greater urgency.
The proposed rule will have minimal impact on the NRC's ability to carry its missions to ensure public health and ;nfety.
The. Commission is issuing' the proposed rule for pubic comment and.has specifically requested comments with respect to assessment' on. incremental reduction in the licensees' resources.
1 Sincerely, Dennis K.-Rathbun, Director Office of Congressional Affairs i
Enclosure:
3 As stated cc:
Representative Carlos J. Moorhead b
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