ML20138H238
| ML20138H238 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/05/1993 |
| From: | Mccabe E NRC |
| To: | NRC |
| Shared Package | |
| ML20138G636 | List:
|
| References | |
| FOIA-96-351 NUDOCS 9701030181 | |
| Download: ML20138H238 (14) | |
Text
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From:
Ebe C. McCabe (ECM1)
To:
KP1:WN1:WN5:ASM Date:
Wednesday, May 5, 1993 11:43 am
Subject:
SALEM NON-CLASSIFICATION OF EMWERGENCIES
- Aby, j
My heartburn remains that 50.72 requires reporting of declared emergencies.
Therefore, classified emergencies which are over and therefore are not declared do not, per the specific wording of j
10CFR50.72, have to be reported as emergencies.
Should OGC provide us an interpretation which contradicts this conclusion, I'd be delighted.
I like the idea of discriminating between emergency classification
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and declaration.
But, that takes us out of the regulatory requirement domain and into the interpretation arena.
I don't think that we can interpret but are stuck with stating, as guidance, that all emergency conditions, including terminated ones, must be declared and reported as such, but that terminated emergencies need not be j
responded to.
We could also issue guidance stating that licensee E-Plans which call for classification and reporting of already terminated emergencies, without otherwise requiring the same response as an ongoing declared emergency, meets notification needs and is an I
acceptable way to meet 50.72, if such provisions are incorporated in the NRC-approved E-Plan, and with the caveat that failure to make a
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timely report (which can be the subject of additional guidance) of the emergency classification does not meet the letter or intent of the regulations (with legal review / concurrence, of course).
We do need a resolution of this issue, particularly for Salem.
Basically, they have refused to incorporate notification of
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terminated emergency conditions.
The question before us is where do we go from here?
Without NRC management support for taking the enforcement action I think is justified, we're stuck.
Jawboning / posturing with a licensee with no ability to enforce equates to trying to force action in excess of requirements -
something we try very hard to avoid.
It leads to discrediting of our inputs by licensees.
Ebe t
9701030181 961226 PDR FOIA O'NEILL96-351 PDR j
l DISCUSSION PAPER ON TERMINATED EMERGENCY AND ANNUNCIATOR LOSS DECLARATION AND REPORTING 4
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e Table of Contents 1.
B a c k g ro u n d................................
-Page 1-2.
Basic Considerations
-Page 1-1 3.
-Page 2-1 l
4.
Previous NRC Manneement Direction............................ -Pag e 2 -
5.
Existine Guidance to Licensees
-Page 3-I 6.
Terminated vs Annunciator Loss Emergencies.....
-Page5-7.
Classification.................
-Page5-
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l 8.
Reporting Terminated Emereencies......
-Page 5-l 9.
Licensee Emereeney Plan Provisions
-Page 6-10.
Precedent Event at Vermont Yankee
-Page 6-3 11.
ProDosed Reportine of Terminated Events.......
-Page 7-12.
Safety-Related vs. Important-to-Safety
-Page 8-
-Page 8-j 13.
12/28/92 NRC Memorandum...
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DISCUSSION PAPER TERMINATED AND ANNUNCIATOR LOSS EMERGENCIES 1,
Hackeround Handling of emergency conditions that are over when identified (or before being reported) has been a recurrent problem. This paper was written to provoke related discussion at the January 11-12, 1993 Emergency Preparedness counterpart meeting. Please note that the hasty preparation means that its statements and their bases may be wrong and must be viewed with skepticism.
(The quotes haven't been confirmed to be fully accurate, and many statements should actually be questions.) It is the discussion and the additional points brought out there, and not this working tool, that determines the merit of the issues.
2.
Basic Considerations The considerations used to develop this paper include the following.
Declaring an emergency when none exists can cause over-reaction. There is even a small potential for adversely impacting the response to a different emergency. On the other hand, not declaring an emergency may preclude timely review of the safety significance of the associated event and of the propriety of the licensee's response.
The NRC requires adherence to emergency plans and implementing procedures. Not only is that an application of the definition of a requirement, permitting noncompliance encourages it. Further,10CFR50.54(x) authorizes reasonable departure from licensed conditions / technical specifications in an emergency ifimmediately necessary to protect public health and safety. Otherwise, noncompliance is not permitted.
The NRC considers open and candid communications with States, local governments, licensees, and the public to be essential to NRC credibility. A corollary implication is that we should not appear to inhibit or eliminate communications about emergencies.
Doing so, even to avoid over-reaction, should be expected to be received adversely. Also, we should expect those who determine and/or implement protective actions for the public to feel a need to asms all emergencies, including terminated ones.
Achieving and maintaining credibility, internally and externally, requires consistent application and interpretation of requirements. To act otherwise hazards being perceived as arbitrary and capricious, and that limits effectiveness. Past applications and interpretations should be changed when appropriate, but such changes should be carefully
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developed and clearly promulgated, internally and externally, to minimize the adverse impact. Further, such changes are best made as a result of self-analysis rather than as situational expedients; expediency too can be detrimental to credibility.
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-Page l-
3.
F.nforcement Policy A key consideration is what the NRC enforcement policy states in this regard. 10CFR50.2 Appendix C Supplement VIII.C specifies.
" Severity III - Violations involving for example:
- 1. In an alert, licensee failure to promptly (1) correctly classify the event, (2) make required notifications to responsible Federal, State, and local agencies, or (3) respond to the event (e.g., assess actual or potential offsite consequences, activate emerge:,cy response facilities, and augment shift staff), or
- 2. Licensee failure to meet or implement one emergency planning standard involving assessment or notification."
When a licensee does not promptly identify and report an Alert, a Severity Level III violation may be appropriate. The root cause may be failure to identify the event, but the above OR-gated Commission policy seems to oblige the NRC staff to evaluate failure to report an Alert as a potential escalated enforcement ar' ion. (Failure to report a Site Area Emergency must be i
evaluated as a potential Severity II violation. These obligations exist even though neither the quoted policy nor the referenced emergency planning standards of 10CFR50.47(b) specifically address emergencies that are over when identified.}
4.
Previous NRC Mananement Direction The following rationale on timely classification of nuclear power plant emergencies (11/25/86 James M. Taylor Memorandum to James G. Kepler) seems relevant to this issue.
"The purpose of the emergency classification and action level scheme is to ensure that licensees accurately and promptly assess, classify and notify authorities (editorial emphasis is added in bold type) of an emergency. In its rationale for the final emergency planning regulations, the Commission stated, 'In order to discharge effectively its statutory responsibilities, the Commission firmly believes (emphasis added) that it must be in a position to know that proper means and procedures will be in place to assess the course of an accident and its potential severity, that NRC and other appropriate authorities and the public will be notified promptly (emphasis added), and that appropriate protective actions in response to actual or anticipated condities can and will be taken.' The intent of the regulations is clear - to provide for prompt assessment and notification (emphasis added). The wording in Appendix 1 to NUREG-0654 provides further emphasis on the aspect of promptness in notification of offsite authorities."
j "A plant specific EAL scheme is the mechanism that results in declaration of an emergency class. If plant parameters indicate that conditions have reached (emphasis added) an emergency threshold according to the EAL scheme, a declaration is called for.
If a declaration is not made at this time, the licensee has not implemented or followed its emergency plan.. "
-Page 2-
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"..While the regulations do not cite a specific allowable time limit between event l
occurrence and when an emergency must be declared, I believe that the regulations, the guidance provided in Appendix 1 to NUREG-0654, and the regulatory / enforcement history to date provide an adequate basis for issuing violations to those licensees who delay in classifying, declaring and notifying proper authorities of an emergency condition."
l Note. A related consideration is whether the NRC staff needs to be in a position of being able to I
assess the course of an emergency which is not a nuclear accident, and whether doing that is properly assured if the event is not reported because it is terminated.
5.
Existine Guidance to I,icensees NUREG-0654 Appendix 1 contains the following related wording.
}]NUSUAI, EVENT Egge 1-4: Class Description.
" Unusual events are in process or have occurred (emphasis added) which indicate a potential degradation of the level of safety of the plant."
BLrpj2Eg
" Purpose of offsite notification is to (1) assure that the first step in any response later found to be necessary has been carried out, (2) bring the operating staff to a state of readiness, and (3) provide systematic handling of unusual events information (emphasis added) and decisionmaking."
Licenses _A_q11gns "1.
Promptly inform State and/or local offsite authorities of nature of unusual condition as soon as discovered (emphasis added)."
"5. Close out with verbal summary to offsite authorities; followed by written summary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (emphasis added)"
i Examnle Initiating Conditions.
"11. Indications or alarms on process or effluent parameters not functional in control room to an extent requiring plant shutdown or other significant loss of assessment or communication capability (e.g., plant computer, Safety Parameter Display System, all meteorological information)"
Note: The above exenple:, in general, relate to information provided by non-safety-related equipment.
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-Page 3-
e "15. Other plant conditions exist that warrant increased awareness on the part of a plant operating staff or State and/or local offsite authorities or require plant shutdown under technical specification requirements or involve other than normal controlled shutdown (e.g., cooldown rate exceeding technical specification limits, pipe cracking found during operation)"
AI.ERT fjass Descriotion
" Events are in progress or have occurred (emphasis added) which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels."
Pmpm
" Purpose of offsite alert is to (1) assure that emergency personnel are readily available to respond if situation becomes more serious or to provide confirmatory radiation monitoring if required, and (2) provide offsite authorities current status information (emphasis added)."
Licensee Actions
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"1. Promptly inform State and/or local authorities of alert status and reason for alert as soon as discovered (emphasis added)"
"8. Close out or recommend reduction in emergency class by verbal summary to j
offsite authorities followed by written summary within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of closcout or class j
reduction (emphasis added)"
Eg_mple Initiating Conditinns "14. Most or all alarms (annunciators) lost" SITE AREA EMERGENCY QMs Description
" Events are in progress or haveiscurred which involve actual or likely major failures of plant functions needed for protection of the public. Any releases not expected to exceed EPA Protective Action Guideline except near site boundary."
-Page 4-
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BLIP &E
"..(5) provide updates for the public through offsite authorities."
l liGsDEthGliDRS "1. Promptly inform State and/or local offsite authorities of site area emergency status and reason for emergency as soon as discovered (emphasis added)"
"10. Close out or recommend reduction in emergency class by briefing of offsite authorities at EOF and by phone followed by written summary within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of closcout or class reduction (emphasis added)"
Example Initiating Conditions "12. Most or all alarms (annunciators) lost and plant transient initiated or in progress" The preceding sections of NUREG-0654 are very consistent with requiring classification and reporting of emergencies that are over before having being reported and with the provisions of the Taylor memorandum. Further, they are inconsistent (particularly close out provisions) with not classifying and declaring terminated emergencies (e.g., closing out an unclassified / undeclared emergency is somewhat illogical).
6.
Terminated vs Annunciator 1 oss Emergencies Another consideration is than there is a mingling of separate issues in this paper - declaring terminated emergencies, reporting terminated emergencies, and safety significance of annunciator losses. That mingling needs to be very carefully considered, lest the implications of one produce invalid generic applications of one or both the others.
7.
Classification Both the industry and the NRC tally and assess emergencies. The NRC typically begins its assessment with review of the emergency report. Overall, tally inaccuracy goes up and the associated NRC assessments may not begin for unclassified emergencies. The safety significance of an event typically involves how long the associated safety degradation lasted, how bad the safety decrease was, and how vulnerable to recurrence such events are. Failure to detect a safety-significant event before it ends does not mean that the event was less serious. Such a failure could even indicate greater safety vulnerability because of the potential for undetected safety degradations. Therefore, isn't classification of all identified emergency conditions needed
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whether or not the associated emergencies end before their identification and reporting?
8.
Reportine Terminated Emergencies l
If no immediate off-site agency or NRC response is appropriate, terminated emergencies at the Site Area Emergency and lower levels may not need the same timeliness of govemmental j
response as ongoing emergencies. There is a consequent implication that the reporting of such
-Page 5-
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emerFancies need not be as quick as the reporting of ongoing emergencies. But, isn't timely NRC review of the emergency classification, response, and closeout needed? Isn't timely reactive NRC assessment of related conditions or phenomena appropriate? Don't timely classification and reporting need to be required to be permit timely accomplishment of the NRC's job?
It could be non-conservative to eliminate reporting of emergencies just because their identification was so tardy or difficult that the emergency ended before reporting it was practicable. The bases for and/or generic implications of that tardiness or difficulty may merit prompt identification to the NRC Further, reporting terminated emergencies to the NRC and to State and local authorities is consistent with the previously quoted statement that the Commission firmly believes that, in order to effectively discharge its statutory responsibilities, it must be in a position to know that NRC and other appropriate authorities will be notified promptly. (This is intended to L
be a literal application of the Commission statement, without modification through interpretation.)
Is this a valid consideration?
i If we deviate from the literal meaning of the existing Commission policy and statements, and from associated NRC guidance, doesn't the Commission need to agree that we do so? If the Commission wants a specific discrimination between ongoing and terminated emergencies or a reporting discrimination between emergencies which are nuclear accidents and emergencies which j
are not nuclear accidents, isn't Commission approval of non-reporting of terminated emergencies virtually assured?
t 9.
Licensee Emernency Plan Provisions j
Many Region I licensees address the communication of an emergency that is over before it can be reported by procedurally requiring that a terminated emergency be reported as such, in the same time frame and by the same means as if it still existed when recognized. (The Salem i
licensee appears to be an exception from most other Region I licensees in this regara.) No specific written NRC promulgation of this criterion is evident, but the NRC approval of
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emergency plans with such provisions constitutes existing NRC endorsement of this approach.
This approach appears to satisfy NRC, State and local government needs, the enforcement policy, and the provisions of NUREG-0654. (Such reporting presumes NRC and State and local government capabilities that will prevent unnecessary responses. That presumption considers the i
organizations that determine and implement protective actions for existing emergencies to also be able to properly respond to emergencies that have ended.)
10.
Precedent Event at Vermont Yankee On 4/24/82, there was a loss of feedwater at Vermont Yankee. Decreasing Reactor water level resulted in a scram, MSIV isolation, and HPCI actuation (for about one minute). The scram was reported to the NRC but HPCI was initially reported to the NRC as not having actuated (the Shift Supervisor did not recognize that HPCI had actuated when he made this report). The OI investigation documented the shift supervisor's statement that he had not recognized that the HPCI injection required an Alert declaration until about three hours after the event was over. He then contacted the plant manager, who decided not to declare an Alert or advise the State authorities. The rationale was that the event had ended about three hours earlier and the plant j
was in stable shutdown. OI also concluded that the reluctance to declare the Alert was
-Page 6-b
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compounded by what the licensee viewed as the strict nature of the State requirements for reporting alert conditions. No evidence of wrongdoing or careless disregard for Commission regulations and/or requirements was identified.
NRC enforcement action (EA 82-112) in this case was a Severity III, $40,000 civil penalty. The enforcement action noted that the event evaluation and reporting failures did not involve willfulness or careless disregard, or an adverse affect on public health and safety. The civil penalty was imposed to emphasize the importance of ensuring that operators properly evaluate events, including changes in the status of safety related equipment, that the Nuclear Safety Engineer function is properly implemented (he knew that IIPCI had actuated), and that events are promptly recognized, classified, and reported to off-site officials.
The civil penalty violation citation was for failure to properly evaluate a loss of feedwater event which initiated ECCS and for the associated failure to recognize and classify this event in accordance with the emergency plan.
Notes: The AND gate requiring prompt identification, classification, and reporting of emergencies is a common thread in the record. It does seem, however, that it's really prompt identification of emergencies that's the core issue. Because we do not require licensees to report conditions they don't know about, the failure to report when identified may have been the best available regulatory tool. It may even be that the resolution we need is to require licensees to have effective mechanisms in place ihr identifying emergencies, and to enforce that when this issue recurs again.
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It has been rumored that this civil penalty involved for special circumstances, and that this precedent may therefore not be a good one. But, that does not seem material to the present issue. Most licensees, at least in Region I, review civil penalties at other sites and take action to prevent vulnerability to the same charges. Good or bad, such precedents result in generic (though non-uniform) licensee emergency plan changes. Consequently, we need to make sure that changing the message delivered by an escalated enforcement action is worth the down side of the inconsistency projected by the message change, 11.
Proposed Reportine of Terminated Even,ty t
NRR:EPB has proposed that a terminated emergency not be declared but be reported by the same means and in the same time after identification as an ongoing emergency. That satisfies many needs. But,10CFR50.72 does not require reporting undeclued emergencies, and a report consequently might not be made to State and local officials. Whether associated conditions require a 50.72 or 50.73 report to the NRC is uncertain as well, and determining just what is and what is not so required to be reported could be difficult. Among the many listed required but not clearly defined reports are a major loss of emergency assessment capability, of off-site response capability, or of communications capability (e.g., loss of a significmt portion of control room indication, the ENS, or the off-site notification system). While this identifies some non-safety-l related equipment as being required to be reported to the NRC when lost, there is much variance in what individuals may view as major and/or significant. Is this a potential regulatory quagmire in the field?
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-Page 7-l
l The preceding paragraph is consistent with the licensee's position on the recent Salem loss of l
annunciators: feedback from the resident inspector who identified the event the following day was I
that the licensee saw no need to make any report at all on the loss of these non-safety-related I
annunciators to the NRC or to State and local officials. Does making this EPB proposal into NRC staff policy mean that we will have decided to not implement the as written enforcement l
policy? Doesn't it also mean that licensees who classify terminated emergencies as such will appear to have more emergencies than those who do not so report, and that we can therefore expect generic elimination of such provisions from licensee EAL schemes? Doesn't this have implications that far exceed the annunciator significance?
12.
Safety-Related vs. Imnortant-to-Safety In the preceding, NRC safety interest in non-safety-related equipment is evident. Prior to the TMI-2 accident, there was close to a binary NRC focus on safety-related equipment and i
activities, as listed by the licensee, being regulatable. Non-safety-related equipment and activities were often not regulated despite the provision in 10CFR50 Appendix B that activities that affect the ability of safety-related structures, systems, and components to perform their safety function had to be controlled consistent with their importance to safety. (An early NRC safety guide contained a graduated level of safety significance / classification rather than a binary one; but graduated safety / quality assurance provisions do not seem to have received general implementation into enforceable provisions.)
After the TMI-2 accident, non-safety-related auxiliary feedwater systems were upgraded considerably and made safety-related in most aspects / cases. But, the TM1-2 core thermocouples that read high during the accident and the associated core damage implications were rejected by the licensee for some time. The stated (at least on-site) reason provided by the licensee was that the thermocouples were not safety-related and were therefore not reliable. PWR core j
thermocouples are still non-safety-related, as are many other equipments and activities that are important to safety. The associated safety implications led to the NRC identifying safety-related as a subset of important-to-safety and to an agency focus on safety importance rather than just on specific identification as being safety-related and/or included in the safety analyses that show that safe shutdown can be gained and maintained.
j Focusing only on designated safety-related equipment and activities is particularly specious when emergency preparedness is considered. If the safety-related designations and safety analyses were sufficient, there would have been no TMI-2 event and there also would be no need for emergency preparedness. We need to avoid regression to the pre-TMI syndrome that not being safety-related and/or not being in the safety analysis connotes the discounting of equipment or activity importance to assuring plant safety. Unfortunately, old ways die hard, and people tend to return to earlier ways _of thinking as time dims the importance of hard-learned lessons. Isn't that a reason why history tends to repeat itself7 13.
12/28/92 NRC Memorandum Recently, a Deputy EDO memorandum was issued to the Regional Administrators and the NRR, i
AEOD, and OE Directors. That memorandum appears to be based on NRC staffinputs which l
are significantly narrower in perspective than are the implications of the preceding sections of this
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paper Therefore, the provisions of that memorandum are treated in the following from a devil's
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advocate viewpoint for the purpose of stimulating discucion.
i Memorandum 31atement i
Based on the guidance in NUREG-0654/ FEMA-REP-1, and at the urging of the staff years ago, many licensees have classified " Loss of Annunciators" as an Alert for Emergency Action Level Statements. As you are aware, one of the main purposes of the ALERT is to advise offsite authorities to 1) augment resources and bring primary response centers and EBS to standby status and 2) place key emergency personnel, monitoring teams and communications personnel in a standby status. The class description for ALERT is defined in 0654 as, " Events are in progress or have occurred which involve an actual or potential substantial degradation of the level cf safety in the plant. Any release expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels."
Comments /Ouestians The " Class Description" states that events are in progress or have occurred. Isn's the "or have occurred" phrase clearly applicable to terminated events? Further,isn't the definition quite clear that no significant off-site impact is or was involved? Shouldn't that limit the reaction to the report that such an event had occurred and was over?
What specific untoward off-site responses have occurred as a result of the actual reporting of terminated emergencies that has occurred since the Vermont Yankee civil penalty?
Statement The following is an excerpt from a recent inspection report pertaining to the loss of all annunciators for about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while the plant was in steady state power operation:
Safety Sinnificance The annunciator system is not a safety-related system and is not considered in any of the licensee's safety analyses. During this event, safety-related instrumentation was still i
available to monitor important plant parameters. Automatic safety systems were unaffected during the event and were available to shut down and cool the reactor if required. The plant was stable and no significant systems were out of service during the event. Based upon the above information, this loss of annunciator event posed no significant threat to public or plant safety. However, this event is considered significant because of the licensee's failure to recognize and enter an ALERT EAL despite clear and convincing evidence of the extent of the annunciator problems Comments /Ouestians Isn't the annunciator system not being safety-related an incomplete consideration? Doesn't how important to safety the annunciator system is also need addressing? Aren't many safety-
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significant operator actions based on the annunciator information they continually use and respond to? Can annunciator loss be assumed to be unimportant to safety? Could l
I alarms / annunciators prompt an operator to not secure safety injection improperly, or to restore it quickly, and thereby avert core melting like the TMI-2 accident?
It may be that, in the specific case in point, the operators were properly trained to handle, and fully capable of proficiently combatting, plant emergencies without the annunciators while I
implementing the emergency plan proficiently. But, at many plants the operating staffis very strongly challenged to implement emergency notifications and respond to plant conditions when the annunciators are working propes!y, end several Region I plants have beefed up their operating I
staffs as a result. Did the inspection and report address these considerations? Are we being treated to an out-(,f-context portion of the inspection and report?
l Cannot essentially the same statement about safety-related and safety analysis categorization be l
made about virtually any non-safety-related system, including the hardware and control and management systems instituted incident to the TMI Action Plan? Doesn't this approach to safety (as distinct from the specific annunciator loss case) toss out important-to-safety systems as being l
of importance to safety? If not, why isn't the safety importance addressed?
The conclusion that failure to recognize the requirement for entry into the emergency plan is l
significant seems quite correct. It shows that the operators, in at least one case, did not implement their BALs as required. Moreover, the 12-hour duration of this occurrence similarly indicts plant management. Did the inspection / report address these considerations? Were the l
operators and managers well-trained in recognizing all emergency plan entry conditions? What j
performance testing measures did the licensee use to assure that? Were they sufficient? (This is l
not an area in which Region I licensees uniformly excel, but it is one that several are upgrading.)
l Memorandum Statement s
l In light of the foregoing, it is questionable whether a loss of annunciators should be classified as an Alert and it clearly does not appear to appropriate to take escalated enforcement action for failure to make such a declaration when the conditions intended to be established by the declaration are not desirable.
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Comments /Ouestions Whether a loss of annunciators should be declared an Alert seems to be a function of their i
importance to safety, including fulfillment of Commission-endorsed notification provisions and timely initiation of appropriate governmental responses / reviews under particularly challenging conditions. Should declaring a terminated Alert cause inappropriate staffing or response rather than appropriately prompt licensee and govemmental review? Doesn't properly implementing NRC responsibilities connote assuring that the responses to declared emergencies will be proper l
rather than to eliminate declaration of emergencies because there reay be over-reaction? Are we proposing a band-aid fix rather than a correction of the root problem (s)? If we are in error, is j
that error on the side of conservatism? Shouldn't it be?
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l Doesn't whether a Site Area Emergency or an Alert or an Unusual Event is the proper response to l
a loss of annunciators and associated conditions need consideration of the bases for inclusion of those provisions in NRC guidance? Don't operator licensing inputs need consideration as well?
l Those two sets of inputs may support a conclusion that there is no safety importance to alarms and indicators, but aren't they the key to just what importance the alarms and annunciators have to operating safety and/or emergency response capabilities?
If, as the memorandum implies, the annunciators aren't significant to assuring nuclear safety and/or protecting the public, shouldn't we make the licensees remove them because they can distract the operators from using the safety-related equipment relied upon in the safety analyses?
Shouldn't we do the same for other non-safety-related equipment and activities?
Are we opening the doors for licensees to downgrade their controls over non-safety-related but important-to-safety equipments and activities? Why?
Is it really undesirable that the NRC and State and local govemments be specifically required to be promptly informed that an emergency went undetected at a nuclear power plant? Is it acceptable that the precedent requirement for that reporting be tossed out? Do we have reasonable assurance that the precedent position will not be reverted to in the future?
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Do we actually consider either the NRC cr State and local govemments to be likely to respond improperly to such notifications? Or that licensees will be overtaxed by reporting Alerts? If so, can we conclude that we and they can properly respond to the more serious events that will tax our and their capabilities more severely and under greater pressure?
Under this new direction, how do we assure that the reporting we want will be achieved? Is that reporting an enforceabli requirement? Based on what? Also, since declarations of terminated emergencies have been a rather common practice, what specific cases of improper responses support the view that they should not be declared?
Are we playing big brother to protect others from being unnecessarily scared? Further, will the j
redirection actually reduce training in emergency plan implementation in such a way that valid training in not over-reacting is eliminated?
The memorandum, in effect, directs that not declaring and reporting a terminated emergency not be considered for escalated enforcement action. What are the implications in regard to Severity Level IV violations? to subsequent escalated enforcement for repetition and the associated necessity for enforcement conferences?
Without an enforceable requirement for timely reporting of terminated emergencies, how is the i
associated systematic handling of reporting emergencies affected? (NUREG-0654 Unusual Event l
wording is explicit on this purpose, but the feature is inherent to higher emergency classifications l
as well.)
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