ML20138H246
| ML20138H246 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 06/11/1993 |
| From: | Mccabe E NRC |
| To: | Kanton F NRC |
| Shared Package | |
| ML20138G636 | List: |
| References | |
| FOIA-96-351 NUDOCS 9701030186 | |
| Download: ML20138H246 (10) | |
Text
__
1 >
l l
l From:
Ebe C. McC e
ECM1)
To:
WN5(FXK)
O
Date:
Friday, June 11, 1993 10:27 am
Subject:
TERMINATED EMERGENCY DECLARATION / REPORTS 1
- Falk, I've attached my comments on revising NUREG-1022.
(That's related to our pending, and late, Salem / Hope Creek report.)
This ravision can oblige us to not enforce declaration or reporting of terminated emergencies unless licensees voluntarily require such reporting in their plans / procedures.
Further, non-reporting of terminated emergencies is likely to proliferate because those who report will have more emergencies and look less safe.
And, revising NUREG-0654 via NUREG-1022 is confusing - unless 0654 is changed too.
We may need to modify and clarify the regulations, but let's not make our guidance more conflicting.
In any case, I'd appreciate EPB comment on the specific correctness / error of the also attached proposed Salem
& Hope Creek report wording.
Ebe CC:
WN5(ASM, RAE1)
Files:
G:\\eps\\rgsec311.rev P
i i
).
O'NEILL96-351 PDR
.. o.
The following is PEPB's recommendation for revising Section 3.1.1 l
l of NUREG-1022, Revision 1, Page 24.
l l
3.1.1 10 CFR 50.72 Immediate Notification Requirements for Operating Nuclear Reactors Infrequently a declaration on rare occasions, a recort of an emergency is may be required after the fact.
An event or condition, which meets the criteria for classification into one of the four emergency classes in the emergency plan, may not be reported or be recognized as reportable until after the event is i
over or the condition corrected, and the plant is in a stable, safe condition.
This delay can be up from a few minutes to a few I
weeks.
Causes include a rapidly concluded event, an oversight in emergency classification made during an event, or a technical discovery found during a post-event review days or weeks later.
In these cases, the emergency classification (usually a Notification of Unusual Event) event or condition is to be declared slassified and reported, as such, under this criteria within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery of the emergency declaration requirement. that the event or condition meets emeraency classification criteria.
This will initiate the appropriate licensee and NRC reviews of the reportable event or condition.
Termination of the emergency classification should be made in accordance with the licensee's emergency procedures and S50.72 (c) (1) (iii) discussed in Section 3.4.3 of this document.
This does not mean that an ameroency must be " declared" after the fact when it no lonaer exists.
However, the event or condition should be o_ronerly classified and recorted to the NRC within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery under 10 CFR 50.72.
State and local Anthorities should also be notified as soon as is oractical, or in accord &nge with arranaements made in advance.
Comments.
There are the follcwing two different provisions to the above:
l That a terminated emergency is to be classified and reported as such, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery.
That a terminated emergency should be proporly classified l
and reported to the NRC within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery under l
State and local authorities should also be notified...
i In the above provisions, is to be appears to be a mandate.
That implication is, however, negated by the subsequent statement that uses should instead of is to be.
(Many years ago, I discovered that the nuclear industry had defined shall (a requirement),
should (recommended but not required), and may (optional).
This usage of should is different than the common one, which associates a duty or obligation with the word.
Because of the
e 1 :
potential connation within the industry, we need to be careful of how we use should, and to make sure any obligatory implications are clearly identified.]
While the inconsistency in the wording of the proposed revision to NUREG-1022 needs to be resolved, a revision to a NUREG is not a regulatory requirement and does not resolve whether terminated emergencies must be declared or reported.
In fact, the proposed revision can be viewed as negating (through providing a basis for licensees modifying their emergency plans and/or for the NRC not enforcing the existing plans and procedures) existing requirements in licensee plans for reporting terminated emergencies as such in the same time frame as ongoing ones.
In fact, from a bean-counting approach, licensees who do report emergencies that others don't report are vulnerable to being classified as less safe, and that consideration alone could cause widespread licensee incorporation of non-reporting of terminated emergencies.
Not declaring and reporting emergency conditions that end before reporting is accomplished might eliminate the following from being declared and reported to the NRC.
(UE) Short-term ECCS initiation and discharge to the vessel.
(UE) Short-term excesses of radiological effluent technical specification limits.
(UE) Short-term excursions involving abnormal coolant temperature and/or pressure, or abnormal fuel temperature.
(UE) Short-term losses of off-site power or of on-site AC power capability (e.g., during shutdown or low power operation).
(UE) Short-term in-plant fires that last over 10 minutes (e.g.,
15-minute fires).
('UE ) A quickly aborted attempted unauthorized entry into the facility.
(UE) Earthquakes felt in-plant (a typical earthquake duration is 10-15 seconds).
(Al) Short-term loss of off-site power and on-site AC power.
(Al) Short-term loss of all on-site DC power.
(A1) Short-term loss of any function needed for cold shutdown.
l (A1) Short-term radiological effluent releases greater than 10X the technical specification instantaneous limits.
(SAE) Loss of off-site power and loss of on-site AC power for a short period in excess of 15 minutes.
(SAE) Loss of all vital on-site DC power for a short period in excess of 15 minutes.
(SAE) Short-term loss of any function needed for hot shutdown (including repetitive / cyclic occurrences?).
(SAE) Short-term fire compromising the functions of safety systems (e.g.,
one which necessitates shifting RPS to a two-out-of-three trip configuration instead of a three-out-of-four configuration?)
(SAE) Evacuation of control room with control of shutdown systems not established from local stations for a short period in excess of 15 minutes.
Also, isn't the one-hour reporting criterion of 10CFR50.72 for non-emergency conditions?
Are we going to ask licensees to classify terminated events / conditions as emergencies and then to report them as non-emergencies?
I'm not sure whether the revised wording means that the NRC demands, expects, or prefers terminated emergency classification and reporting.
But, I see no regulatory basis for enforcing classification and reporting of terminated emergencies unless declaration of terminated emergencies is required by a licensee's aproved emergency plan.
Is my conclusion correct?
)
I think I've been expressing the same concern about this issue for several months now, with no answer received and no change evident in the approach being taken.
We have an overdue inspection report on Salem and Hope Creek, in part due to this issue, that I need to move on.
In that regard, I plan to submit the following for concurrence / issue with that inspection report, and would appreciate EPB comments on whether that's an acceptable approach.
FORWARDING LETTER PARAGRAPE This inspection also followed-up on EP considerations identified j
incident to the November 1992 Salem loss of annunciator event.
I Although that event was not a safety significant one, associated review concluded that your emergency declaration and reporting procedures do not appear to conform to the NRC and FEMA guidance contained in the " Class Description" sections of Appendix 1 to l
NUREG-0654/ FEMA-REP-1, in that emergency declarations are not required by you for events that have occurred as well as those which are in progress.
As a result, no reporting of terminated l
emergency events is prescribed by your emergency plan and j
procedures.
This appears to provide a blanket elimination of j
declaration and reporting of short duration emergencies and of emergencies discovered after the fact.
So doing can prevent NRC l
and off-site authority event review for safety significance and follow-up, as well as avert notification of senior licensee management that an emergency condition occurred and/or went i
,__.,_m
l' undetected.
An associated implication is that such events, which may have generic implications, do not become part of the industry and NRC records of facility emergencies.
Please review these considerations and advise us in writing, within 45 days of receiving this letter, of the safety justification for your practice or, if such is the case, of your plans to change your j
plan and procedures to assure adequate identification of the i
emergency conditions of concern.
INSPECTION REPORT PARAGRAPH 2.
Non-Declaration of Terminated Emergencies The most significant concern about the EP program since the last EP program 'espection was the Event Classification Guide (ECG) provisions that became apparent after the December 1992 loss of overhead annunciator system in the Salem Unit 2 control room.
During that event, operators promptly restored the system upon discovery, and the need for emergency augmentation of the on-shift staff was thereby eliminated.
An NRC Augmented Inspection Team found that plant conditions existed for an Alert declaration prior to recognition, but no emergency classification or declaration was made, nor was there timely notification of the existence of the emergency condition to the States of New Jersey and Delaware or to the NRC.
In this case, the precribed emergency classification was an Alert for a loss of annunciators.
Since, from a safety viewpoint, that loss of annunciators did not have the safety significance of an Alert, that specific non-declaration was not of safety importance.
In the general case, however, non-declaration of terminated emergencies does not appear to meet the NRC and FEMA guidance contained in the " Class Description" sections of Appendix 1 to NUREG-0654/ FEMA-REP-1.
Specifically, the first sentence of the Class Description for each of the four emergency levels specifies that the events "are in progress or have occurred."
The licensee indicated that non-declaration of a terminated gf
]* g"*'
emergency was appropriate because declaration of an Alert or higher condition requires a staff augmentation response.
NRC review noted, however, that prompt declaration and reporting of terminated emergencies without requiring the staff augmentation prescribed for ongoing emergencies has been accomplished by other licensees.
In such a case, for example, a licensee can declare an " Alert-Terminated" and make the associated reports without automatic call-out of the Emergency Response Organization (ERO).
NRC review also identified the following reasons for declaring terminated emergencies.
Emergency declaration and reporting provides a timely l
trigger for licensee senior management, State and local, and l
NRC assessment of event significance, of the appropriateness l
of the licensee's action, and of the need for further follow-up.
Declaration and reporting of an emergency results in its
inclusion in industry and NRC records of emergency l
conditions, and in associated assessments of the safety l
import of the emergency conditions which occur at nuclear i
power plants.
Failure to declare and report emergency conditions could lead to non-identification of licensee inability to accomplish timely identification of defined emergency conditions.
In this case. the licensee revised their Emergency Classification Guide to specify one-hour notification of the NRC and State when a major loss of assessment capability not exceeding an emergency action level was determined to occur.
That does not fully address the above concerns.
Therefore, this item is unresolved pending further licensee and NRC review of the safety significance of declaration of terminated emergencies.
(UNR 50-272/93-13-01; 50-311/93-13-01; and 50-354/93-09-01).
l l
1
The following is PEPB's recommendation for revising Section 3.1.1 of NUREG-1022, Revision 1, Page 24.
3.1.1 10 CFR 50.72 Immediate Notification Requirements for Operating Nuclear Reactors hfrequc;:!y a de:h=:ica On rare occasions. a renort of an emergency is may be required after the fact. An event or condition, which meets the criteria for classification into one of the four emergency classes in the emergency plan, may not be reported or be recognized as reportable until after the event is over or the condition corrected, and the plant is in a stable, safe condition. This delay can be up from a few minutes to a few weeks. Causes include a rapidly concluded event, an oversight in emergency classification made during an event, or a technical discovery found during a post-event review days or weeks later.
In these cases, the emergency !=iS=tica ( =lly : "ctiS=:!c cf U==! Sc=:) event or condition is to be deelated classified and reported. as such. under4 hie-eriteria within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery of th::==gemy 6:!= 10: =quir..=:. that the event or condition meets emergency cinalfication criteria. This will initiate the appropriate licensee and NRC reviews of the reportable event or condition. Tem.im !c cf th;:=ugscy ciniS=Sc should be.-
!= = c-d=c whh th: !!c==': :=cg;=y p==&=: =d $50.72(c)(1)(iii) dis uned in Sectica 3.4.3 cf :hi: dc;;==:. This does not mann that an amernency must be " declared" after the fact when it no lonaer erlats. However. the event or condition should be nronerly cinalfled and renorted to the NRC within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discavery under 10 CFR 50.72. State and local authorities should also be notified as soon as is n_ ractical.
or in accordance with arrana*ments made in advance.
l Comments.
There are the following two different prmisions to the above:
e That a terminated emergency is to be classified and reported as such, within I hour of l
discovery.
That a terminated emergency should be properly classified and reported to the NRC e
within I hour of discovery under 10CFR50.72. State and local authorities should also be notified...
In the above provisions, is to be appears to be a mandate. That implication is, however, negated by the subsequent statement that uses should instead of is to be. [Many years ago, I discovered that the nuclear industry had defined shall (a requirement), should (recommended but not required), and may (optional). This usage of should is different than the common one, which associates a duty or obligation with the word. Because of the potential connation i
within the industry, we need to be careful of how we use should, and to make sure any obligatory implications are clearly identified.]
I e
While the inconsistency in the wording of the proposed revision to NUREG-1022 needs to be resolved, a revision to a NUREG is not a regulatory requirement and does not resolve whether terminated emergencies must be declared or reported. In fact, the proposed revision can be viewed as negating (through providing a basis for licensees modifying their i
emergency plans and/or for the NRC not enforting the existing plans and pincedures) existing requirements in licensee plans for reporting terminated emergencies as such in the same time frame as ongoing ones. In fact, from a bean-counting approach, licensees who l
do report emergencies that others don't report are vulnerable to being classified as less safe, and that considention alone could cause widespread licensee incorporation of non-reporting of terminated emergencies.
Not declaring and reporting emergency conditions that end before reporting is accomplished might eliminate the following from being declared and reported to the NRC.
l l
(UE) Short-term ECCS initiation and discharge to the vessel.
e l
e (UE) Short-term excesses of radiological effluent technical specification limits.
I (UE) Short-term excursions involving abnormal coolant temperature and/or pressure, e
l or abnormal fuel tempenture.
(UE) Short-term losses of off-site power or of on-site AC power capability (e.g.,
e during shutdown or low power operation).
(UE) Short-term in-plant fires that last over 10 minutes (e.g.,15-minute fires).
e (UE) A quickly aborted attempted unauthorized entry into the facility.
e l
l e
(UE) Earthquakes felt in-plant (a typical earthquake duration is 10-15 seconds).
l l
e (Al) Short-term less of off-site power and on-site AC power.
i (Al) Short-term loss of all on-site DC power.
l e
(A1) Shoit-term loss of any function needed for cold shutdown.
e (Al) Short-term radiological effluent releases greater than 10X the technical specification instantaneous limits.
(SAE) I.oss of off-site power and loss of on-site AC power for a short period in e
excess of 15 minutes.
e (SAE) Loss of all vital on-site DC power for a short period in excess of 15 minutes.
j e
(SAE) Short-term loss of any function needed for hot shutdown (including repetitive / cyclic occurrences?).
(SAE) Short-term fire compromising the functions of safety systems (e.g., one which e
l necessitates shifting RPS to a two-out-of-three trip configuration instead of a three-out-of-four con 0guration?)
(SAE) Evacuation of control room with contml of shutdown systems not established e
from local stations for a short period in excess of 15 minutes.
Also, isn't the one-hour reporting criterion of 10CFR50.72 for non-emergency conditions?
Are we going to ask licensees to classify terminated events / conditions as emergencies and then to report them as non-emergencies?
I'm not sure whether the revised wording means that the NRC demands, expects, or prefers terminated emergency classincation and reporting. But, I see no regulatory baais for enforcing classification and reporting of terminated emergencies unless declaration of terminated emergencies is mquired by a licensee's apmved emergency plan. Is my conclusion correct?
I think I've been expressing the same concern about this issue for several months now, with no answer received and no change evident in the appmach being taken. We have an overdue inspection report on Salem and Hope Creek, in part due to this issue, that I need to move on.
In that regard, I plan to submit the following for concurrence / issue with that inspection report, and would appreciate EPB comments on whether that's an acceptable approach.
FORWARDING LETTER PARAGRAPH' This inspection also followed-up on EP considerations identified incident to the November 1992 Salem loss of annunciator event. Although that event was not a safety significant one,
)
associated review concluded that your emergency declaration and reporting procedures do not appear to conform to the NRC and FEMA guidance contained in the " Class Description" sections of Appendix 1 to NUREG-0654/ FEMA-REP-1, in that emergency declarations are not required by you for events that have occurred as well as those which are in progress. As j
a result, no reporting of terminated emergency events is prescribed by your emergency plan and pmcedures. This appears to provide a blanket elimination of declaration and reporting of short dumtion emergencies and of emergencies discovered after the fact. So doing can prevent NRC and off-site authority event review for safety significance and follow-up, as well as avert notification of senior licensee management that an emergency condition occurred and/or went undetected. An associated implication is that such events, which may have generic implications, do not become part of the industry and NRC records of facility emergencies. Please review these considerations and advise us in writing, within 45 days of I
receiving this letter, of the safety justification for your practice or, if such is the case, of your plans to change your plan and procedures to assure adequate identification of the emergency conditions of concern.
l l
l
I INSPECTION REPORT PARAGRAPII 2.
Non-Declaration of Terminated Emergencies The most significant concern about the EP program since the last EP program inspection was the Event Classification Guide (ECG) provisions that became upparent after the December 1992 loss of overhead annunciator system in the Salem Unit 2 control room. During that event, operators promptly restored the system upon discovery, and the need for emergency augmentation of the on-shift staff was thereby eliminated. An NRC Augmented Inspection Team found that plant conditions existed for an Alert declaration prior to recognition, but no emergency classification or declaration was made, nor was there timely notification of the existence of the emergency condition to the States of New Jersey and Delaware or to the NRC. In this case, the precribed emergency classification was an Alert for a loss of annunciators. Since, from a safety viewpoint, that loss of annunciators did not have the safety significance of an Alert, that specific non-declaration was not of safety importance. In the general case, however, non-declaration of terminated emergencies does not appear to meet the NRC and FEMA guidance contained in the " Class Description" sections of Appendix 1 to NUREG-0654/ FEMA-REP-1. Specifically, the first sentence of the Class Description for each of the four emergency levels specifies that the events "are in progress or have occurred."
The licensee indicated that non-declaration of a terminated emergency was appropriate because declaration of an Alert or higher condition requires a staff augmentation response.
NRC review noted, however, that prompt declaration and reporting of terminated emergencies without requiring the staff augmentation prescribed for ongoing emergencies has been accomplished by other licensees. In such a case, for example, a licensee can declare an "Alett-Terminated" and make the associated reports without automatic call-out of the Emergency Response Organization (ERO). NRC review also identified the following reasons for declaring terminated emergencies.
Emergency declaration and reporting provides a timely trigger for licensee senior 5
management, State and local, and NRC assessment of event significance, of the appropriateness of the licensce's action, and of the need for further follow-up.
Declaration and reporting of an emergency results in its inclusion in industry and e
NRC records of emergency conditions, and in associated assessments of the safety import of the emergency conditions which occur at nuclear power plants.
Failure to declare and report emergency conditions could lead to non-identification of licensee inability to accomplish timely identification of defined emergency conditions.
In this case. the licensee revised their Emergency Classification Guide to specify one-hour notification of the NRC and State when a major loss of assessment capability not exceeding an emergency action level was determined to occur. That does not fully address the above concerns. Therefore, this item is unresolved pending further licensee and NRC review of the safety significance of declaration of terminated emergencies. (UNR 50-272/93-13-01; 50-311/93-13-01; and 50-354/93-09-01).
.