ML20207N455

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Discusses Timeliness of Classifying Emergencies at Nuclear Power Facilities.Appears That Info Notice 85-080 Alone Was Not Sufficient to Cause Licensee to Promptly Classify Event & Notify Appropriate Govt Ofc.Related Info Encl
ML20207N455
Person / Time
Site: Davis Besse, LaSalle, 05000000
Issue date: 08/14/1986
From: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Taylor J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20204G677 List:
References
FOIA-86-729, RTR-NUREG-0654, RTR-NUREG-654 IEIN-85-080, IEIN-85-80, NUDOCS 8701140230
Download: ML20207N455 (100)


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UNITED STATES ff N Y NUCLEAR REGULATORY COMMISSION g 4 REGION Ill O S '

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AUG 141986 i MEMORANDUM FOR: J. M. Taylor, sirector, Office of Inspection and Enforcement FROM: James G. Keppler, Regional Administrator Region III ,

SUBJECT:

TIMELINESS OF CLASSIFYING EMERGENCIES AT NUCLEAR POWER FACILITIES Appendix E to 10 CFR Part 50 clearly indicates that a licensee must be capable of notifying State and County officials within 15 minutes after declaration of an Unusual Event, Alert, Site Area Emergency or General Emergency. However, i

the regulations fail to specify a time limit regarding how much time may elapse between the occurrence of an event and the time the licensee makes a classification. The only available guidance in this area is provided in Appendix 1 df NUREG-0654, Revision 1, which recomends that prompt notification of offsite authorities is intended to mean within about 15 minutes for the Unusual Event class and sooner (consistent with the need for other emergency actions) for other classes. The time is measured from the time at which operators recognize that events have occurred which make declaration of an emergency class appropriate. Although the guidance appears to clarify the regulation, the NUREG-0654 interpretation is only " guidance" and a licensee cannot be held accountable to that interpretation.

Several instances have occurred in Region III over the last year or so where this has become an issue. The first was the incident at Davis Besse on June 9, 1985. During this incident the licensee actually passed through an Alert (loss of all auxiliary feedwater) and then delayed an initial notification of an Unusual Event for ten to fifteen minutes beyond when it should have been declared after the feedwater was restored. A second example occurred on May 19, 1986 at Palisades. In this instance a total of 89 minutes elapsed from the time that adequate information was available for the licensee to classify the incident as an Unusual Event and the time when the event was actually classified. When the notifications were made subsequent to this declaration.

l they were simply to inform the State and local agencies that the licensee had been in an Unusual Event but had since deescalated from it.

A third example of inadequate notification relates to the LaSalle Unit 2 potential ATWS condition that occurred on June 1, 1986. Our review of this

' incident indicated that while the licensee took some very conservative actions (e.g., terminated the power increase at 7:32 a.m. and comenced shutdown at 2:15 p.m.) the licensee did not use the ENS telephone to notify IE Headquarters Operations Officer until 6:45 p.m.

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In each of the above cases, a violation was not issued to the licensee since no '

regulatory requirement hadb.een violated. However, delays of this nature could have significant impact on the NRC Incident Response capability and can subject the NRC to considerable criticism when we fail to respond. This concern has 4 obviously not gone unnoticed in the past as evidenced by the publication of IE Information Notice No, 85-80, Timely Declaration of an Emergency Class, Implementation of an Emergency Plan, and Emergency Notifications, dated October 15, 1985. This Notice discussed the incident at Davis Besse and stressed the importance of initiating emergency preparedness actions as soon as conditions warrant, and that delaying the response can defeat the appropriate response to an emergency. However, it appears that Information Notice No. 85-80 alone was not sufficient to cause licensee's to promptly classify an event and notify the appropriate government office. l

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1 10 CFR 50.72 reporting requirements states that licensee's are required to contact the NRC Operations Center of the declaration of any-emergency class per the licensee's emergency plan. We note there is no discussion related to the timeliness of the declaration, after the event has occurred. Further 2 examination of 10 CFR 50.72 shows that 50.72(b) states that for non-emergency i events, "If not reported as a declaration of an Emergency Class under paragraph j (a) of this section, the licensee shall notify the NRC as soon as practical and n all cases within one hour of the occurrence of any of the following:".

Essentially, this means we have a regulatory requirement to notify the NRC within one hour of the occurrence of a non-emergency event, but there is no regulatory requirement to notify the NRC or any offsite agency within a specified time limit from the occurrence of an event that is classifiable as an emergency. .

Region III recommends that action be taken to amend the regulations in the area of emergency preparedness to require a licensee to declare an emergency class as soon as events have occurred that can be identified as being classified as an emergency condition as described in the licensee's Emergency Action Levels.

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hJamesG.Keppler Regional Administrator cc: T. E. Murley, I J. N. Grace, RI R. D. Martin, RIV J. B. Martin, RV E. Jordan, IE

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2 IMMEDIATE NOTIFICATION RULE l50.72  :

ERIC W. WEISS EVENTS ANALYSIS BRANCH DIVISION OF EMERGENCY PREPAREDNESS & ENGINEERING RESPONSE OFFICE OF INSPECTION AND ENFORCEMENT 1

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UNITED STATES

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, 5 l JAN 2 31984 MEMORANDUM FOR: C. J. Heltemes, Jr., Director Office for Analysis and Evaluation of Operational Data FROM: Richard C. DeYoung, Director Office of Inspection and Enforcement

SUBJECT:

QUESTIONS AND ANSWERS ON THE NEW LER RULE In response to your memorandum on this subject dated January 3, 1984, we have -

reviewed the questions and answers that you propose to publish as a supplement to NUREG-1022, " Licensee Event Report Syste n."

We propose that IE and AE00 jointly publish the supplement to NUREG-1022 as a document that explains and amplifies both 10 CFR 50.72, "Immediate Notification Requirements of Significant Events At Operating Nuclear Power Reactors," and 10 CFR 50.73, " Licensee Event Report (LER) Rule." This is appropriate since these two rules share many of the same reporting criteria and have Deen closely coordinated in terms of their scope and impact on licensees. We have attached some additional questions and answers that would permit you to publish the In addition, we suggest that proposed NUREG in a form that covers both rules.

each question regarding a reporting requirement in 10 CFR 50.73 be cros:; refer-enced to the similar reporting requirement in 10 CFR 50.72. The supplementary NUREG would be an appropriate place to publish the preamble to the Federal Register Notice for 50.72 in a nanner analogous to the way that the preamble to the Federal Register Notice for 50.73 was published in NUREG-1022.

We have a specific comment regarding question 6.2--whether a rod block is reportable--because the person asking the question contends that the rod block monitor (RBM) is designated an engineered safety feature (ESF) at a particular boiling water reactor (BWR). We believe the answer to this question should be amplified by adding the words: "Unless the rod block monitor (RBM) is classi-fied as a portion of the reactor protection system (RPS) or as an engineered safety feature (ESF), rod blocks need not be reported."

We believe the answer to question 7.24 should be amplified by adding the words:

"The event would also be reportable if the offsite power that is lost is required for safety functions when shut down."

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l C. J. Heltemes t We believe the supplementary NUREG that you propose to publish would be an ap-propriate place to include a memorandum from the Executive Director for Operations (EDO) to the licensees regarding an exemption under 50.73(g) for exclusion from reporting the following item in BWRs:

Inoperability of only one of the following:

Reactor core isolation cooling (RCIC), or high pressure coolant injection (HPCI), or high pressure core spray (HPCS).

We have also enclosed the answer to question 8.2 which was left blank in the draft that you sent us.

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Richard C. Young, Director Office of Inspection and Enforcement

Enclosure:

As stated cc: R. Minogue, RES G. Cunningham, ELD J. Davis, NMSS F. Hebdon, AE00 L. Cunningham, IE J. Buchanan, IE

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, Additional Questions and Answers on 10 CFR 50.72 and 10 CFR 50.73 50.72 - General Question:

It is difficult to instruct an operator how to implement the specific reporting requirements of 50.72. The regulations are words, yet the explanation is by example. Would it not have been better to have more examples?

Answer:

It is correct that the regulations do not include examples and may need amplification in plant procedures. The information contained in this supple-mentary NUREG does, hcnever, contain specific examples.

Comments on the regulations themselves can be submitted at any time and should be submitted where a regulation can be improved or needs to be changed to assure safety.

50.72 - General Question:

There seem to be three categories of reports - 15 minutes to offsite organizations; one hour to the NRC; or as soon as possible after reporting to offsite agencies.

Can you clarify this?

Answer:

Reports should be made as soon as practical and in no case later than the regulatory deadlines. Different deadlines are provided so that more time is permitted for events of less safety significance.

Paragraph 50.72(b)(1)(1)(A)

Question:

Maintenance is required on a safety-related component and, as a result, the component is not available. A limiting condition for operation (LCO) is then entered. In order to fix the problem it is necessary to reduce power but not to shut down. Must we report via the emergency notification system (ENS) when we reduce power?

Answer:

Yes. If the plant is in a LCO and must reduce power, it should be reported, even though the shutdown was not completed and even though the power reduction may be necessary only to fix a component rather than to meet the requirements of the LCO to shut down.

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, 2 Paragraph 50.72(b)(2)(vi)

Question:

You indicated that some events need not be reported if there is no anticipated press interest. We may not know whether a press release will or will not be issued within four hours. What should we do?

Answer:

A report should be made within four hours of a decision to issue a press release.

Paragraph 50.72(b)(1)(v)

Question:

What is meant by a major loss of emergency assessment capability? For example, would loss of the Safety Parameter Display System (SPDS) be reportable?

Answer:

A major loss of emergency assessment capability would include those events that significantly impair the licensee's safety assessment capability. Some engineering judgement is needed to determine the significance of the loss of

. particular equipment. Loss of only the SPDS for a short period of time need not be reported, but loss of SPDS and other assessment equipment at the same time may be reportable.

Paragraph 50.72(b)(1)(v)

Question:

What is meant by a major loss of offsite response capability? For example, would the loss of one siren for a short period of time warrant making an immediate notification to the NRC?

Answer: -

A major loss of offsite response capability would include those events that would significantly impair the fulfillment of the licensee's approved emergency plan. Although loss of a single siren for a short period of time is not a major loss of offsite response capability, the loss of a large number of sirens or more importantly the loss of the capability to alert a large segment of the population for a period of one hour, would warrant an immediate notification.

Paragraph 50.72(b)(2)(iv) and 50.73(a)(2)(viii)

Question:

What meteorological data should be used in determining offsite concentrations

(e.g., annual average, real time or worst case)?

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Annual average meteorological data shouid be used for determining offsite

  • airborne concentrations of radioactivity. This is to maintain consistency with the technical specifications.

Paragraph 50.72(b)(2)(iv) and 50.73(a)(2)(viii)

Question:

What location should be used as the point for release calculation purposes (e.g. , unrestricted area as defined by Part 20 or the expanded definition as specified in NUREG-0133 " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants [A Guidance Manual for Users of Standard Technical Specifications]")? .

Answer:

The expanded definition of an unrestricted area as specified in NUREG-0133 should be used. This is to maintain consistency with tNe technical specifications.

Paragraph 50.72(b)(2)(vi)

Question:

If we are required to make routine reports to the Environmental Protection Agency (EPA) regarding routine effluent release data, are we required to .nake immediate notification to the NRC?

Answer:

No. Routine reports on effluents need not be reported under the immediate notification requirements. If, however, there is a particular effluent release that has safety significance, or is expected to generate public, media, or other agency attention as a result of being unusual or abnormal, then an immediate notification to the NRC would be warranted.

Answer to Question 8.2:

No. Releases of mixtures of radionuclides are treated in accordance with the

" Note to Appendix B" of 10 CFR Part 20. Paragraph 1 of the " Note" provides for summing of the fractional maximum permissible concentration (MPC) values for the radionuclides known to be present in the mixture. Paragraphs 2, 3, and 4 of the " Note" provide concentration limits for cases in which the identity or the concentration of any radionuclide is not known. Paragraph 5 of the

" Note" provides for conditions under which a radionuclide may be considered not to be present in a mixture.

I IMMEDIATE NOTIFICATION RULE l50,72 ERIC W. WEISS EVENTS ANALYSIS BRANCH DIVISIONOkEMERGENCYPREPAREDNESS&ENGINEERINGRESPONS 0FFICE OF INSPECTION AND ENFORCEMENT h a s6-729 4}'l

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NRC REGIONAL MEETING ON THE LICENSEE EVENT REPORT SYSTEM j INTRODUCTION

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C. J. HELTEMES, DIRECTOR OFFICE FOR ANALYSIS AND EVALUATION 0F OPERATIONAL DATA l

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THE USE OF THE LICENSEE EVENT REPORT

- THE LER IS THE PRINCIPAL MEANS FOR:

- MONITORING THE FREQUENCY OF SAFETY PROBLEMS.

- STUDYING POTENTIAL ACCIDENT PRECURSORS.

- ASSESSING RISK CONTRIBUTIONS.

- THE LER IS USED BY:

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INDEPENDENT CONSULTANTS AND FIRMS

- NRC CONTRACTORS

- FOREIGN ORGANIZATIONS THUS, THE LER IS ONE OF THE MOST IMPORTANT, MOST WIDELY READ, AND MOST WIDELY USED DOCUMENTS IN THE INDUSTRY.

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S NUREG-1022, LICENSEE EVENT REPORT SYSTEM CONTENTS:

- THE LER RULE.

- A BRIEF DESCRIPTION OF HOW LERS ARE ANALYZED BY THE NRC.

- A RESTATEMENT OF THE GUIDANCE CONTAINED IN THE STATEMENT OF CONSIDERATION THAT ACCOMPANIED THE PUBLICATION OF THE LER RULE.

- GENERAL AND SPECIFIC GUIDANCE ON HOW TO PREPARE AN LER.

- THE LER FORMS.

- A SET OF EXAMPLES OF POTENTIALLY REPORTABLE EVENTS WITH STAFF COMMENTS ON THE ACTUAL REPORTABILITY OF EACH EVENT.

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OTHER USES OF LER DATA STUDY OF COMMON CAUSE FAILURE DATA.

STUDY OF FAILURE RATE DATA FOR COMPONENTS.

STUDY OF SYSTEMS INTERACTIONS.

- STUDY OF HUMAN ENGINEERING AND MAINTENANCE.

STUDY OF PROBLEMS WITH CURRENT PROCEDURES.

STUDY OF PRECURSOR IDENTIFICATION AND ASSESSMENT.

STUDY OF FAULT TREE / EVENT TREE CONSTRUCTION / VALIDATION.

STUDY OF POTENTIAL GENERIC SAFETY ISSUES.

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USES OF OPERATIONAL EXPERIENCE (CONTINUED)

LER ANALYSIS AND EVALUATION PROGRAM NRC SCREENS EACH LER TO:

IDENTIFY THOSE EVENTS OR GENERIC SITUATIONS THAT WARRANT ADDITIONAL ANALYSIS.

IDENTIFY EMERGING TRENDS OR PATTERNS OF POTENTIAL SAFETY SIGNIFICANCE.

A PATTERN OR TREND CAN ORIGINATE FROM:

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- A SINGLE ENGINEER REVIEWING AN INDIVIDUAL LER AND' RECALLING FROM MEMORY SIMILAR EVENTS IN OTHER REPORTS, l - THE LER IDENTIFYING PREVIOUS OCCURRENCES.

- A PRIORI POSTULATION OF A CONCERN.

- THE STATISTICAL TRENDS AND PATTERNS PROGRAM BEING DEVELOPED BY AE00 IS

-DRIVEN BY THE DATA.

- NOT DEPENDENT ON THE PRIOR FORMULATION OF A PARTICULAR CONCERN.

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a e NRC FEEDBACK DOCUMENTS THAT USE LER INFORMATION AE00 ENGINEERING EVALUATIONS AND CASE STUDIES IE BULLETINS AND INFORMATION NOTICES NRR GENERIC LETTERS, SPECIAL REPORTS, AND SRP REVISIONS

- POWER REACTOR EVENTS ABNORMAL OCCURRENCE REPORTS TO CONGRESS LER COMPILATION

- NRC CONTRACTOR REPORTS NRC STAFF REPORTS PRINT 0UTS FROM COMPUTERIZED DATA FILES

- IRENDS AND PATTERNS

SUMMARY

REPORTS.

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'J r OVERVIEW 0F THE REVISED LER SYSTEM

- BASIS IMPROVE LERS FOR OPERATING EXPERIENCE FEEDBACK TO CONFIRM SAFETY MARGINS AND IDENTIFY SAFETY PROBLEMS.

- REVISIONS

- CRITERIA ARE BASED PRIMARILY ON THE NATURE, COURSE, AND CONSEQUENCES OF THE EVENT.

- EVENTS ARE REPORTED REGARDLESS OF THE PLANT OPERATING MODE OR POWER LEVEL.

- REPORTS CONTAIN A DETAILED NARRATIVE DESCRIPTION OF POTENTIALLY SIGNIFICANT SAFETY EVENTS.

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IHE REVISED LER SYSTEM FREDERICK J. HEBDON, CHIEF, PROGRAM IECHNOLOGY BRANCH, 0FFICE FOR ANALYSIS AND EVALUATION OF OPERATIONAL DATA l

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OPERATIONS PR0HIBITED BY THE TECHNICAL SPECIFICATIONS PARAGRAPH 50 73(A)(2)(1)

"(A) THE COMPLETION 0F ANY NUCLEAR PL ANT SHUTDOWN REQUIRED BY THE PLANT'S TECHNICAL SPECIFICATIONS; OR (B) ANY OPERATION PROHIBITED BY THE PLANT'S TECHNICAL

. SPECIFICATIONS, OR (C) ANY DEVIATION FROM THE PL ANT'S IECHNICAL SPECIFIC ATIONS AUTHORIZED PURSUANT TO 550 54(x) 0F THIS PART."

1 "UPERATIONS PROHIBITED" (I.E., VIOLATIONS) DOES NOT INCLUDE l ENTERING AN LC0 IF THE CONDITIONS OF THE LC0 ARE MET.

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OVERVIEW OF THE REVISED LER SYSTEM (CONTINUED)

- EXPECTED RESULTS

- FEWER LERS (ABOUT 50% LESS)

REPORTS ONLY OF SIGNIFICANT EVENTS

- BETTER REPORTS (MORE USEFUL)

- LICENSEES ARE PERMITTED AND ENCOURAGED TO REPORT ANY EVENT THAT DOES NOT MEET THE CRITERIA CONTAINED IN 550 73(A), IF THE EVENT

- MIGHT BE OF SAFETY SIGNIFICANCE,

- MIGHT BE OF GENERIC INTEREST OR CONCERN,

- CONTAINS A LESSON TO BE LEARNED.

ENGINEERING JUDGMENT (CONTINUED)

PARAGRAPH 50 73(A)(2)(III)

"ANY NATURAL PHENOMENON OR OTHER EXTERNAL CONDITION THAT POSED AN ACTUAL THREAT TO THE SAFETY OF THE NUCLEAR POWER PLANT OR SIGNIFICANTLY HAMPERED SITE PERSONNEL IN THE PERFORMANCE OF DUTIES NECESSARY FOR THE SAFE OPERATION OF THE NUCLEAR POWER PLANT."

- LICENSEE IS TO DECIDE IF A PHENOMENON OR CONDITION " POSED AN ACTUAL THREAT" TO THE PLANT.

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ENGINEERING JUDGMENT PARAGRAPH 50 73(A)(2)(II)

"ANY EVENT OR CONDITION THAT RESULTED IN THE CONDITION OF THE NUCLEAR POWER PLANT, INCLUDING ITS PRINCIPAL SAFETY BARRIERS, BEING SERIOUSLY DEGRADED, OR THAT RESULTED IN THE NUCLEAR POWER PLANT BEING:

(A) IN AN UNANALYZED CONDITION THAT SIGNIFICANTLY COMPROMISED PLANT SAFETY; (B) IN A CONDITION THAT WAS OUTSIDE THE DESIGN BASIS OF THE PLANT; OR (C) IN A CONDITION NOT COVERED BY THE PLANT'S OPERATING AND EMERGENCY PROCEDURES."

- LICENSEE MAY USE ENGINEERING JUDGMENT AND EXPERIENCE TO DETERMINE WHETHER AN EVENT IS REPORTABLE UNDER THIS CRITERION.

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ENGINEERING JUDGMENT (CONTINUED)

PARAGRAPH 50 73(A)(2)(x)

"ANY EVENT THAT POSED AN ACTUAL THREAT TO THE SAFETY OF THE NUCLEAR POWER PLANT OR SIGNIFICANTLY HAMPERED SITE PERSONNEL IN THE PERFORMANCE OF DUTIES NECESSARY FOR THE SAFE OPERATION OF THE NUCLEAR POWER PLANT INCLUDING FIRES, T0XIC GAS RELEASES, OR RADIOACTIVITY RELEASES."

- LICENSEE IS TO DECIDE IF AN EVENT POSED AN ACTUAL THREAT TO THE i PLANT OR SIGNIFICANTLY HAMPERED SITE PERSONNEL.

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ENGINEERING JUDGMENT (CONTINUED)

PARAGRAPHS 50 73( A)(2)(v) AND (vl)

"(v) ANY EVENT OR CONDITION THAT ALONE COULD HAVE PREVENTED THE FULFILLMENT OF THE SAFETY FUNCTION OF STRUCTURES OR SYSTEMS THAT ARE NEEDED TO:

(A) SHUT DOWN THE REACTOR AND MAINTAIN IT IN A SAFE SHUTDOWN CONDITIONJ (B) REMOVE RESIDUAL HEATJ (C) CONTROL THE RELEASE OF RADIOACTIVE MATERIAL) OR (D) MITIGATE THE CONSEQUENCES OF AN ACCIDENT.

(VI) EVENTS COVERED IN PARAGRAPH (A)(2)(V) 0F THIS SECTION MAY INCLUDE ONE OR MORE PERSONNEL ERRORS, EQUIPMENT FAILURES, AND/OR DISCOVERY OF DESIGN, ANALYSIS, FABRICATION, CONSTRUCTION, AND/OR PROCEDURAL INADEQUACIES. HOWEVER, INDIVIDUAL COMPONENT FAILURES NEED NOT BE REPORTED PURSUANT TO THIS PARAGRAPH IF REDUNDANT EQUIPMENT IN THE SAME SYSTEM WAS OPERABLE AND AVAILABLE TO PERFORM l THE REQUIRED SAFETY FUNCTION."

- A TECHNICAL JUDGMENT MUST BE MADE WHETHER A FAILURE OR OPERATOR ACTION THAT DID ACTUALLY DISABLE ONE TRAIN OF A SAFETY l SYSTEM, COULL HAVE, BUT DID NOT, AFFECT A REDUNDANT TRAIN WITHIN THE ESF SYSTEM.

- REPORTABLE IF THERE IS REASONABLE DOUBT THAT THE FUNCTION-ALLY REDUNDANT TRAIN OR CHANNEL WOULD REMAIN OPERATIONAL UNTIL IT COMPLETED ITS SAFETY FUNCTION OR WAS REPAIRED.

l l

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MEETING TOPICS

- MONITORING FOR CONSISTENT INTERPRETATION AND IMPLEMENTATION.

- ENFORCEMENT OF LER REPORTING REQUIREMENTS.

- QUALITY OF REPORTING AND IMPACT ON LER REVIEW PROGRAMS.

- ENGINEERING JUDGMENT IN IDENTIFYING REPORTABLE EVENTS.

REGIONAL COMMENTS ON THE LER SYSTEM, PARTICULARLY NUREG-1022,

" LICENSEE EVENT REPORT SYSTEM."

- SELECTED TOPICS FROM THE LER RULE

- NARRATIVE FORMAT

- ENERGY INDUSTRY IDENTIFICATION SYSTEM

- EXEMPTIONS

- REPL ACEMENT OF EXISTING IECHNICAL SPECIFICATION REPORTING REQUIREMENTS i

. - ,, -._-.., - -__ - - ~_- - . - - - , _ , . . . - . -

IMPACT ON RELATED REPORTING REQUIREMENTS 10 CFR PART 20 STANDARDS FOR PROTrrTION AGAINST RADIATION 520 402 REPORTS OF THEFT OR LOSS OF LICENSED MATERIAL IN 520 402, PARAGRAPH ( A) HAS BEEN REVISED; THE INTRODUCTORY TEXT OF PARAGRAPH (B) HAS BEEN REVISED) AND A NEW PARAGRAPH (E) HAS BEEN ADDED TO READ AS FOLLOWS:

(A)(1) EACH LICENSEE SHALL REPORT TO THE COMMISSION, BY TELEPHONE, IMMEDIATELY AFTER IT DETERMINES THAT A LOSS OR THEFT OF SUCH CIRCUMSTANCES THAT IT APPEARS TO THE LICENSEE THAT A SUBSTANTIAL HAZARD MAY RESULT TO PERSONS IN UNRESTRICTED AREAS.

(2) REPORTS MUST BE MADE AS FOLLOWS:

(1) LICENSEES HAVING AN INSTALLED EMERGENCY NOTIFICA-TION SYSTEM SHALL MAKE THE REPORTS TO THE NRC OPERATIONS CENTER IN ACCORDANCE WITH 550 72 0F THIS CHAPTER.

(II) ALL OTHER LICENSEES SHALL MAKE REPORTS TO THE ADMINISTRATOR OF THE APPROPRIATE NRC REGIONAL OFFICE LISTED IN APPENDIX U OF THIS PART.

(B) EACH LICENSEE WHO MAKES A REPORT UNDER PARAGRAPH ( A) 0F THIS SECTION SHALL, WITHIN 30 DAYS AFTER LEARNING OF-THE LOS3 OR THEFT, MAKE A REPORT IN WRITING TO THE U.S.

NUCLEAR REGULATORY COMMISSION, DOCUMENT CONTROL DESK, WASHINGTON, D.C. 20555, WITH A COPY TO THE APPROPRIATE NRC REGIONAL OFFICE LISTED IN APPENDIX D OF THIS PART.

THE REPORT SHALL INCLUDE THE FOLLOWING INFORMATION:

IMPACT ON RELATED REPORTING REQUIREMENTS (CONTINUED) 520<402 REPORTS OF THEFT OR LOSS OF LICENSED MATERIAL (CONTINUED)

(E) FOR HOLDERS OF AN OPERATING LICENSE FOR A NUCLEAR POWER PL ANT, THE EVENTS INCLUDED IN PARAGRAPH (B) 0F THIS SECTION MUST BE REPORTED IN ACCORDANCE WITH THE PROCEDURES DESCRIBED IN PARAGRAPHS 50 73(B), (C), (D), (E), AND (G) 0F THIS CHAPTER AND MUST INCLUDE THE INFORMATION REQUIRED IN PARAGRAPH (B) 0F THIS SECTION. EVENTS REPORTED IN ACCORDANCE WITH 550 73 0F THIS CHAPTER NEED NOT BE REPORTED BY A DUPLICATE REPORT UNDER PARAGRAPH (B) 0F THIS SECTION.

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IMPACT ON RELATED REPORTING REQUIREMENTS (CONTINUED) 10 CFR 20 402 - NO CHANGE IN REPORTING CRITERIA

- TELEPHONE NOTIFICATION VIA THE ENS

- WRITTEN REPORT BY LER 10 CFR 20 403 - NO CHANGE IN REPORTING REQUIREMENTS

- TELEPHONE NOTIFICATION VIA THE ENS 10 CFR 20 405 - NO CHANGE IN REPORTING REQUIREMENTS

- WRITTEN REPORT BY LER 10 CFR PART 21 - REVISION IN PROGRESS

- REPORTING CRITERIA CONSISTENT WITH 50 72 AND 50 73 10 CFR 50 36 - NO CHANGE IN REPORTING REQUIREMENTS

- TELEPHONE NOTIFICATION VIA THE ENS

- WRITTEN REPORT BY LER 10 CFR 50 55(E) - REVISION IN PROGRESS

- REPORTING CRITERIA CONSISTENT WITH 50 72 AND 50 73 10 CFR 73 71 - REVISION IN PROGRESS

- REPORTING CRITERIA CONSISTENT WITH 50 72 AND 50 73

-,. -- . - - - . , , . . . - ., - - - - - . , . - . . , , - - . . . ---.-.,.,--n... -- - , . , - . . - -

t CONTENT OF THE LER

- 50 73(s) THE LICENSEE EVENT REPORT SHALL CONTAIN:

- 50 73(a)(1) A BRIEF ABSTRACT.

- MAJOR OCCURRENCES.

l - ALL COMPONENT FAILURES.

I

- SIGNIFICANT CORRECTIVE ACTION.

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. - _ , . . . _ . , . . . . . _ _ . . , _ _ _ . , - _ _ , . . . _ , _ , _ _ _ _ . _ _ . _ . _ _ _ . , , _ . - . . . , _ _ _ _ . . . _ _ , _ _ . _ , . . , . _ . ._.____.-,__.._..-___,._._.______r- _ _ _ _ _ ,_ _ , , _ _ _ __ _..

CONTENT OF THE LER (CONTINUED) 50 73(B)(2)(I) A CLEAR, SPECIFIC, NARRATIVE DESCRIPTION OF WHAT OCCURRED SO THAT KNOWLEDGEABLE READERS CONVERSANT WITH THE DESIGN OF COMMERCI AL NUCLEAR POWER PL ANTS, BUT NOT FAMILLIAR WITH THE DETAILS OF A PARTICUL AR PL ANT, C AN UNDERSTAND THE COMPLETE EVENT.

- EMPHASIZE HOW SYSTEMS, COMPONENTS, AND OPERATING PERSONNEL PERFORMED.

- DESCRIBE CHARACTERISTICS OF A PLANT THAT ARE UNIQUE f

AND THAT INFLUENCED THE EVENT.

DESCRIBE THE EVENT FROM THE PERSPECTIVE OF THE OPERATOR.

I

- DO NOT COVER SPECIFIC HARDWARE PROBLEMS IN EXCESSIVE DETAIL.

- DO NOT USE TERMS, INITIALS, OR ACRONYMS THAT ARE i

ONLY IN LOCAL USE.

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c CONTENT OF THE LER (CONTINUED)

- 50 73(B)(2)(II) THE NARRATIVE DESCRIPTION MUST INCLUDE THE FOLLOWING SPECIFIC INFORMATION AS APPROPRIATE FOR THE PARTICULAR EVENT:

- (F) THE ENERGY INDUSTRY IDENTIFICATION SYSTEM COMPONENT FUNCTION IDENTIFIER AND SYSTEM NAME OF EACH COMPONENT OR SYSTEM REFERRED TO IN THE LER.

DEFINED IN IEEE STDS 803-1983, 803A-1983, AND 805-1983

" SYSTEM NAME" MAY BE EITHER THE FULL NAME (E.G.,

REACTOR COOLANT SYSTEM) OR THE TWO LETTER SYSTEM CODE ( E.G ., AB).

- WHEN THE NAME IS LONG THE CODE SHOULD BE USED.

- INCLUDE THE NAME AND/OR CODES IN PARENTHESIS FOLLOWING THE FIRST REFERENCE TO A SYSTEM OR COMPONENT IN THE TEXT OF THE LER.

I

- IHE NAME AND/OR CODE NEED NOT BE REPEATED WITH EACH SUBSEQUENCE REFERENCE TO THE SAME COMPONENT OR SYSTEM.

- 00 NOT INCLUDE THE PARENTHETICAL NAMES OR CODES IN THE ABSTRACT SECTION.

INTERPRETATION OF A SYSTEM BOUNDARY SHOULD BE CONSISTENT WITH THE COMPARABLE SYSTEM DESCRIPTIONS AND INTERPRETATIONS CONTAINED IN THE NPRDS REPORTABLE SYSTEM AND COMPONENT MANUAL.

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CONTENT OF THE LER (CONTINUED) 50 73(B)(3) AN ASSESSMENT OF THE SAFETY CONSEQUENCES AND IMPLICATIONS OF THE EVENT.

INCLUDE THE AVAILABILITY OF OTHER SYSTEMS OR COMPONENTS THAT COULD HAVE PERFORMED THE SAME FUNCTION.

- BASED ON THE CONDITIONS EXISTING AT THE TIME OF THE EVENT.

- ASSESSMENT OF THE EVENT UNDER ALTERNATIVE CONDITIONS MUST BE INCLUDED IF THE INCIDENT WOULD HAVE BEEN MORE SEVERE UNDER REASONABLE AND CREDIBLE ALTERNATIVE CONDITIONS.

50 73(B)(4) A DESCRIPTION OF ANY CORRECTIVE ACTIONS.

- DESCRIBE CORRECTIVE ACTIONS ON SIMILAR OR RELATED COMPONENTS THAT WERE DONE AS A DIRECT RESULT OF THE EVENT.

- DISCUSS WHY PRIOR CORRECTIVE ACTION DID NOT PREVENT RECURRENCE.

ONLY SUBSTANTIAL CHANGES IN THE CORRECTIVE ACTION NEED BE REPORTED AS A SUPPLEMENTAL LER.

50 73(B)(5) REFERENCE TO ANY PREVIOUS SIMILAR EVENTS.

50 73(B)(6) THE NAME AND TELEPHONE NUMBER OF A CONTACT.

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0 INSTRUCTIONS FOR COMPLETING THE LER FORMS GENERAL INSTRUCTIONS

- ERRORS DISCOVERED IN AN LER SHOULD BE CORRECTED IN A REVISED REPORT.

- THE REVISED REPORT SHOULD BE A COMPLETE ENTITY AND NOT CONTAIN ONLY SUPPLEMENTARY OR REVISED INFORMATION.

- A REVISION SHOULD NOT BE USED TO REPORT SUBSEQUENT FAILURES OF THE SAME OR LIKE COMPONENTS.

- ONLY SUBSTANTIAL INFORMATION THAT WOULD SIGNIFICANTLY CHANGE A READER'S PERCEPTION OF THE COURSE OR CONSEQUENCES OF AN EVENT, OR SUBSTANTIAL CHANGES IN THE CORRECTIVE ACTION PL ANNED BY THE LICENSEE NEED BE REPORTED IN A REVISED LER.

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ITEM 6: REPORT NUMBER

- EVENT YEAR.

- BASED ON EVENT DATE, NOT REPORT DATE.

SEQUENTIAL REPORT NUMBER.

- EACH NUCLEAR UNIT SHOULD HAVE ITS OWN SET OF SEQUENTIAL REPORTS NUMBERS.

- BEGIN WITH 001 FOR THE FIRST EVENT THAT OCCURRED IN EACH CALENDAR YEAR.

- FOR EVENTS COMMON TO MORE THAN ONE UNIT OF A MULTIPLE UNIT SITE, ASSIGN THE SEQUENTIAL NUMBER FOR THE LOWEST NUMBERED NUCLEAR UNIT.

IF THE SQUENTIAL NUMBER IS ASSIGNED TO AN EVENT, AND IT IS SUBSEQUENTLY DETERMINED THAT THE EVENT IS NOT REPORTABLE, WRITE A BRIEF LETTER TO THE NRC NOTING THAT "LER NUMBER XXX FOR DOCKET 05000YYY WILL NOT BE USED."

REVISION NUMBER.

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e INSTRUCTIONS FOR COMPLETING THE LER FORM (CONTINUED)

ITEM ll: REPORTING REQUIREMENTS

- CHECK ONE OR MORE BLOCKS DEPENDING ON THE REPORTigr- REQUIRE-MENTS THAT WERE NET BY THE EVENT.

- A SINGLE EVENT CAN MEET MORE THAN ONE REPORTING CRITERIA.

- FOR EXAMPL E:

- IF AS A RESULT OF SABOTAGE [ REPORTABLE UNDER 573 71(B)] A SAFETY SYSTEM FAILED TO FUNCTION

[ REPORTABLE UNDER 550 73( A)(2)(v)] AND THE NET RESULT WAS A RELEASE OF RADIOACTIVE MATERIAL IN A RESTRICTED AREA THAT EXCEEDED THE APPLICABLE LICENSE LIMIT

[ REPORTABLE UNDER 520 405(A)(1)(III)}.

- CHECK 573 71(B), 50 73(A)(2)(v), AND 520 405 (A)(1)(III).

- AN EVENT CAN BE REPORTED AS AN LER EVEN IF IT DOES NOT MEET ANY OF THE SPECIFIC CRITERIA IN 50 73

- "0THER" BLOCK SHOULD BE USED IF A REPORTING REQUIREMENT IS MET THAT IS NOT SPECIFIED IN ITEM 11 FOR EXAMPLE, AN OPTIONAL l REPORT OF AN UNUSUAL EVENT.

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INSTRUCTIONS FOR COMPLETING THE LER FORM (CONTINUED)

ITEM 13: COMPONENT FAILURES FAILURE IS DEFINED AS THE TERMINATION OF THE ABILITY OF AN ITEM TO PERFORM ITS REQUIRED FUNCTION.

INCLUDES COMPLETE AND DEGRADED FAILURES.

- FOR MULTIPLE FAILURES ONLY A SINGLE ENTRY IS REQUIRED IN ITEM 13

- CAUSE: THE ROOT CAUSE OF THE FAILURE FROM APPENDIX 8 0F NUREG-1022

- SYSTEM: FROM IEEE STANDARD 805-1983

- COMPONENT: FROM IEEE STANDARD 803A-1983

- COMPONENT MANUFACTURER:

- FROM THE NPRDS REPORTING PROCEDURES MANUAL.

- MANUFACTURERS THAT ARE NOT INCLUDED IN THE LIST SHOULD BE DESIGNATED X999

- REPORTABLE TO NPRDS: "Y" OR "N".

ADDITIONAL COMPONENT FAILURES MAY BE CODED ON ONE OR MORE FAILURE CONTINUATION SHEETS (NRC-366B) .

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INSTRUCTIONS FOR COMPLETING THE LER FORM (CONTINUED)

ITEM 17: IEXT

- NO PRESCRIBED FORMAT FOR THE LER TEXT.

- WRITTEN IN THE FORMAT THAT MOST CLEARLY DESCRIBES THE EVENT.

- 50 73(B) IS NOT INTENDED AS AN OUTLINE OF THE TEXT FORMAT.

- 50 73(B) SHOULD BE REVIEWED TO INSURE THAT APPLICABLE SUBJECT HAVE BEEN ADEQUATELY ADDRESSED IN THE TEXT.

THE TEXT MAY BE CONTINUED ON ONE OR MORE TEXT CONTINUATION SHEETS (NRC-366A).

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ADMINISTRATIVE REQUIREMENTS

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- 50 73(C) THE COMMISSION MAY REQUIRE THE LICENSEE TO SUBMIT SPECIFIC ADDITIONAL INFORMATION.

- 50 73(D) - AN LER MUST BE SUBMITTED WITHIN 30 DAYS OF DISCOVERY.

- THE LER SHOULD BE SENT TO THE U.S. NUCLEAR REGULATORY COMMISSION, DOCUMENT CONTROL DESK, WA SHI NGTON, D.C. 20555; WITH A COPY TO THE APPROPRIATE NRC REGIONAL OFFICE.

- 50 73(E) THE LER MUST BE OF SUFFICIENT QUALITY TO PERMIT LEGIBLE REPRODUCTION AND MICR0 GRAPHIC PROCESSING.

- 50 73(F) UPON WRITTEN REQUEST FROM A LICENSEE INCLUDING ADEQUATE JUSTIFICATION OR AT THE INITIATION OF THE NRC STAFF, THE NRC EXECUTIVE DIRECTOR FOR OPERATIONS MAY, BY A LETTER TO THE LICENSEE, GRANT EXEMPTIONS.

- 50 73(G) 50 73 REPL ACE (S) ALL EXISTING REQUIREMENTS FOR LICENSEES TO REPORT " REPORTABLE OCCURRENCES" AS DEFINED IN INDIVIDUAL PL ANT TECHNICAL SPECIFICATIONS.

- USUALLY TITLED " PROMPT NOTIFICATION WITH WRITTEN FOLLOWUP" (SECTION 6 918) AND " THIRTY DAY WRITTEN REPORTS" (SECTION 6 9 1 9).

- THE DISCUSSION OF LER REPORTING IN REGULATORY GUIDE 1 16 AND THE INSTRUCTIONS FOR COMPLETING THE EXISTING l LER FORMS IN NUREG-0161 SHOULD NOT BE USED AFTER JANUARY 1, 1984 n ,. - - - , . . - - , , - . . , . . . -.- . , , . - . , - , . , . . . - . . - ,., . . , ,.

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'f IMIEDIATE NOTIFICATION RULE l50.72 1

Erit W. WEISS EVENTS ANALYSIS BRANCH DIVISION OF EMERGENCY PREPAREDNESS & EliGl! LEERING RESPONSE 0FFICE OF INSPECTION AND ENFORCEMENT 1

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IMMEDIATE NOTIFICATION CONTENTS EVENT CLASSIFICATION (EHERGENCY CLASS OR l-HOUR OR 4-HOUR)

PLANT & UNIT TIME & DATE OF EVENT (GIVE TIME ZONE)

RX POWER (IN PERCENT) AT TIME OF EVENT .

__ RX POWER (IN PERCENT) AT TIME OF REPORT ANYTHING UNUSUAL OR NOT UNDERSTOOD STATUS OF SAFETY SYSTEMS

, ESF ACTUATION .

LC0 STATEMENT SI OR ECCS (INITIATING SIGNAL)

RESIDENT INSPECTOR INFORMED CAUSE OF EVENT (CALL BACK IF NOT KNOWN)

SEQUENCE OF ACTIONS OR SYSTEM INTERACTIONS PLANS FOR RX OPERATION

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@50.72 1,'lI1EDI ATE ERIC WEISS (492-4973) IE NOTIFICATION (PUBLISHED) 850.73LER(PUBLISHED) FRED HEBDON 492-4483 AE0D

$50.47 EMERGENCY PLANNING MIKE JAMGDCHIAN (492-7000) RES APPENDIX E TO PART 50 NUREG-0554 (PROPOSED RULE JAN 84)

@50.54LICENSECONDITION 850.55ECDR DON SMITH (492-7000) RES PART~21 DEFECTS (PROPOSED RULE FEB. 84)

PART 73 SECURITY JULIE METZGER 427-4310 NMSS (FALL OF 84) 9 9

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IMMEDIATE NOTIFICATION NO LONGER REQUIREDBY650.72

. WORKER INJURIES NOT RELATED TO RADIATION OR CONTAMINATION LOW LEVEL RELEASES LESS THAN 2 x PART 20 LIMITS AVERAGED DVER ONE HOUR CERTAIN TESTING OR OPERATION RESULTING IN PREPLANNED SCRAMS OR ESF ACTUATIONS d

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. LOW LEVEL RELEASES *

. TRANSPORT OF CONTAMINATED INDIVIDUALS *

. NEWSWORTHY ITEMS *

  • ASSU.'11NG T101 - HOUR CRITERIA OR Ei1ERGENCY CLASS APPLIES.

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l!CENSEE EVENT REPORT WORKSHOP INTRODUCTION C. J. HELTEMES, O! RECTOR OFFICE FOR ANALYSIS AND EVALUATION i 0F OPERATIONAL DATA OCTOBER 25, 1983 4flo

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PARTICIPANTS C. J. HELTEMES, DIRECTOR, OFFICE FOR ANALYSIS AND EVALUATION OF OPERATIONAL DATA -

SHELDON A. SCHWARTZ g DEPUTY DIRECTOR, OlVISION OF EMERGENCY PREPAREDNESS AND tNGINEERING RESPONSE, OFFICE OF INSPECTION AND ENFORCEMENT STEPHEN G. BURNS, DEPUTY DIRECTOR, REGIONAL OPERATIONS

  • AND ENFORCEMENT DIVISION, OFFICE OF THE EXECUTIVE LEGAL DIRECTOR FREDERICK J. HEBDON, CHIEF, PROGRAM IECHNOLOGY BRANCH, OFFICE FOR ANALYSIS AND EVALUATION cr OPERATIONAL DATA ERIC W. WEISS, OFFICE OF INSPECTION AND ENFORCEMENT

AGENDA 8:00-8:30 I N TR ODU'C T I O N/ B A C KG R O UN D/ H I S TO R Y 8:30-9:00 USES OF OPERATIONAL EXPERIENCE 9:00-10:00 LER (10 CFR 50.-75) REPORTING REQUIREMENTS 10:00-10:15 BREAK 10:15-11:30 LER (10 CFR 50 73) REPORTING REQUIREMENTS l (CONTINUED) 11:30-12:00 IMPACT ON RELATED REPORTING REQUIREMENTS 12:00-1:00 LUNCH 1:00-2:00 IMMEDI ATE NOTIFICATION (10 CFR 50 72) REPORTING REQUIREMENTS (IE REPRESENTATIVE) 2:00-3:00 CONTENT OF THE LER 3:00-3:15 BREAK 3:15-4:15 LER REPORT PREPARATION AND SUBMISSIONS 4:15-5:00 OTHER ISSUES EXEMPTIONS DELETION OF EXISTING TECHNICAL SPECIF1-CATION REPORTING REQUIREMENTS STATUS OF REGULATORY 6UIDE 1 16 AND NUREG-0161

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. 1 LER RULEMAKING - HISTORY SEPTEMBER 1979: NUREG 0572, " REVIEW 0F LICENSEE EVENT REPORTS" JANUARY 30, 1980: ADVANCED NOTICE OF PROPOSED RULEMAKING (ANPRM)

TO MAKE NPRDS MANDATORY

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JANUARY 15, 1981: ANPRM ON THE CONCEPT OF INTEGRATED OPERATIONAL EXPERIENCE REPORTING SYSTEM (10ERS)

JUNE 8, 1981: INP0 ANNOUNCED PLANS TO ASSUME RESPONSIBILITY FOR NPRDS OCTOBER 6, 1981: ANPRM DEFERRING 10ERS DECEMBER 31, 1981: PROPOSED 50 73 SENT TO THE COMMISSION MAY 6, 1982: PROPOSED 50 73 PUBLISHED IN FEDERAL REGISTER JUNE 21, 1983: FINAL 50 73 SENT TO THE COMMISSION JULY 26, 1983: FINAL 50 73 PUBLISHED IN THE FEDERAL REGISTER FALL 1983: REGIONAL WORKSHOPS AND LER NUREG JANUARY 1, 1984: 10 CFR 50 73 EFFECTIVE l

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e NUREG-1022, LICENSEE EVENT REPORT SYSTEM CONTENTS:

- THE LER RULE.

- A BRIEF DESCRIPTION OF HOW LERS ARE ANALYZED I:Y THE NRC.

- A RESTATEMENT OF THE GUIDANCE CONTAINED IN THE STATEMENT OF CONSIDERATION THAT ACCOMPANIED THE PUBLICATION OF THE LER RULE.

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- GENERAL AND SPECIFIC GUIDANCE ON HOW TO PREPARE AN LER.

- THE LER FORMS.

- A SET OF EXAMPLES OF POTENTIALLY REPORTABLE EVENTS WITH STAFF COMMENTS ON THE ACTUAL REPORTABIL ITY OF EACH EVENT.

___w.. ,_ . _ _ , _ . . . , _ . . . - _ _ _ . _ . _ . . , , . , . . . , , - - - . _ ~

O THE USE OF THE LICENSEE EVENT REPORT

- THE LER IS THE PRINCIPAL MEANS'FOR:

- MONITORING THE FREQtlENCY OF SAFETY PROBLEMS.

- STUDYING POTENTIAL ACCIDENT PRECURSORS.

- ASSESSING RISK CONTRIBUTIONS.

- THE LER IS USED BY:

- NRC HEADQUARTERS AND REGIONAL OFFICES INPO

- NSSS VENDORS INDEPENDENT CONSULTANTS AND FIRMS

- NRC CONTRACTORS

- FOREIGN ORGANIZATIONS

- THUS, THE LER IS ONE OF THE MOST IMPORTANT, MOST WIDELY READ, AND MOST WIDELY USED DOCUMENTS IN THE INDUSTRY.

USES OF OPERATIONAL EXPERIENCE (CONTINUED)

LER ANALYSIS AND EVALUATION PROGRAM NRC SCREENS EACH LER TO:

IDENTIFY THOSE EVENTS'OR GENERIC SITUATIONS THAT WARRANT ADDITIONAL ANALYSIS.

IDENTIFY EMERGING TRENDS OR PATTERNS OF POTENTIAL SAFETY SIGNIFICANCE.

A PATTERN OR TREND CAN ORIGINATE FROM:

- A SINGLE ENGINEER REVIEWING AN INDIVIDUAL LER AND -

RECALLING FROM MEMORY SIMILAR EVENTS IN OTHER REPORTS,

- THE LER IDENTIFYING PREVIOUS OCCURRENCES.

- A PRIORI POSTULAT10N OF A CONCERN.

THE STATISTICAL TRENDS AND PATTERNS PROGRAM BEING DEVELOPED BY AEOD IS ORIVEN BY THE DATA.

- NOT DEPENDENT ON THE PRIOR FORMULATION OF A PARTICULAR CONCERN.

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OTHER USES OF LER DATA STUDY OF COMMON.CAUSE FAILURE DATA.

STUDY OF FAILURE RATE DATA FOR COMPONENTS.

STUDY OF SYSTEMS INTERACTIONS.

S1UDY OF, HUMAN ENGINEERING AND MAINTENANCE.

STUDY OF PROBLEMS WITH CURRENT PROCEDURES.

STUDY OF PRECURSOR IDENTIFICATION AND ASSESSMENT.

STUDY OF FAULT TREE / EVENT TREE CONSTRUCTION / VALIDATION.

4 STUDY OF POTENTIAL GENERIC SAFETY ISSUES.

Q NRC FEEDBACK DOCUMENTS THAT USE LER INFORMATION AE00 ENGINEERING EVALUATIONS AND CASE STUDIES IE BULLETINS AND INFORMATION NOTICES

- NRR GENERIC LETTERS, SPECIAL REPORTS, AND SRP REVISIONS POWER REACTOR EVENTS ABNORMAL OCCURRENCE REPORTS TO CONGRESS LER COMPILATION NRC CONTRACTOR REPORTS NRC STAFF REPORTS PRINTOUTS FROM COMPUTERIZED DATA FILES IRENDS AND PATTERNS

SUMMARY

REPORTS.

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(

LER REPORTING REQUIREMENTS FREDERICK J. HEBDON g CHIEF, PROGRAM IECHNOLOGY.DRANCH, l OFFICE FOR ANALYSIS AND EVALUATION OF OPERATIONAL DATA I

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Po14-ev24 0lIl .

DVERVIEW 0F THE REVISED LER SYSTEM BASIS IMPROVE LERS FOR OPERATING EXPERIENCE FEEDBACK TO CONFIRM SAFETY MARGINS AND IDENTIFY SAFETY PROBLEMS.

4 REVISIONS

- CRITERIA ARE BASED PRIMARILY ON THE NATURE, COURSE, AND CONSEQUENCES OF THE EVENT.

- EVENTS ARE REPORTED REGARDLESS OF THE PLANT OPERATING MODE OR POWER LEVEL.

- REPORTS CONTAIN A DETAILED NARRATIVE DESCRIPTION OF POTENTIALLY SIGNIFICANT SAFETY EVENTS.

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- ----,w m-, ..,-,.---,,---_.,-----_.__....----_,_.-,.,,._-___-,.w.,m..

- - ~ - -~ _ .- . -.-~ -.._ _ . - , . ,- - - . - - , - , - - - _ - _ - - - - -

o-OVERVIEW 0F THE REVISED LER SYSTEM (CONTINUED)

- EXPECTED RESULTS

- FEWER LERS (ABOUT 50% LESS)

- REPORTS ONLY OF SIGNIFICANT EVENTS

- BETTER REPORTS (MORE USEFUL)

LICENSEES ARE PERMITTED AND ENCOURAGED TO REPORT ANY EVENT THAT DOES NOT MEET THE CRITERIA CONTAINED IN 550 73(A), IF THE EVENT

- MIGHT BE OF SAFETY SIGNIFICANCE,

- MIGHT BE OF GENERIC INTEREST OR CONCERN, t

- CONTAINS A LESSON TO BE LEARNED.

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PARAGRAPH-BY-PARAGRAPH EXPLANATION OF THE LER RULE PARAGRAPH 50 73(A)(2)(I)

COMPARISON OF 50 73 AND 50 72 50 73(A)(2)(1)(A) THE COMPLETION OF ANY NUCLEAR PLANT SHUTDOWN REQUIRED BY THE PLANT'S TECHNICAL SPECIFICATIONS; OR

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(B) ANY OPERATION #

OR CONDITION PROHIBITED BY THE PL ANT S IECHNICAL SPECIFICATIONSJ OR (C) ANY DEVIATION FROM THE PLANT'S IECHNICAL .

SPECIFICATIONS AUTHORIZED PURSUANT TO 550 54(x) 0F THIS PART.

50 72(B)(1)(I)(A) THE INITIATION OF ANY NUCLEAR PLANT SHUTDOWN REQUIRED BY THE PLANT'S TECHNICAL SPECIFICATIONS (B) ANY DEVI ATION FROM THE PL ANT'S TECHNICAL SPECIFICATIONS AUTHORIZED PURSUANT TO 550 54(x) 0F THIS PART.

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PARAGRAPH 50 73(A)(2)(I)

T{

DISCUSSION

"(A) THE COMPLETION OF ANY NUCLEAR PLANT SHUTDOWN REQUIRED BY THE PL ANT'S TECHNICAL SPECIFICATIONSJ OR (B) ANY OPERATION PROHIBITED BY THE PLANT'S IECHNICAL SPECIFICATIONSJ OR (C) ANY DEVIATION FROM THE PLANT'S IECHNICAL SPECIFICATIONS AUTHORIZED PURSUANT TO 550 54(x) 0F THIS PART."

lHCLUDES THE PLANT SHUTDOWNS REQUIRED BECAUSE THE REQUIREMEN OF THE TECHNICAL SPECIFICATIONS WERE NOT MET.

" SHUTDOWN" IS DEFINED AS THE FIRST SHUTDOWN CONDITION REQUIRED BY A LIMITING CONDITION FOR UPERATION (E.G., HOT STANDBY}.

- DOES NOT INCLUDE CONDITIONS CORRECTED BEFORE THE TIME LIMIT FOR BEING SHUTDOWN.

"0PERATIONS PROHIBITED" (1.E., VIOLATIONS) DOES NOT INCLUDE ENTERING AN LCO IF THE CONDITIONS OF THE LCO ARE MET.

. . . , . , - - . - , , n . . . . , . . . . , - - - - - , . -7,.. , _ . - , - , ., ---

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PARAGRAPH 50 73(A)(2)(II)

COMPARISON OF S0 73 AND 50 72 S0 73(A)(2)(II) ANY EVENT OR CONDITION THAT RESULTED IN THE CONDITION OF THE NUCLEAR POWER PLANT, INCLUDING ITS PRINCIPAL. SAFETY BARRIERS, BEING SERIOUSLY DEGRADED, OR THAT RESULTED IN THE NUCLEAR POWER PLANT BEING:

(A) IN AN UNANALYZED CONDITION THAJ SIGNIFICANTLY

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COMPROMISED PLANT SAFETYJ (B) IN A CONDITION THAT WAS OUTSIDE THE DESIGN BASIS OF THE PLANTJ OR (C) IN A CONDITION NOT COVERED BY THE PLANT'S OPERATING AND EMERGENCY PROCEDURES.

S0 72(B)(1)(ll) ANY EVENT OR CONDITION DURING OPERATION THAT RESULTS IN THE CONDITION OF THE NUCLEAR POWER PLANT, INCLUDING ITS PRINCIPAL SAFETY BARRIERS,

,, BEING SERIOUSLY DEGRADEDJ OR RESULTS IN THE NUCLEAR POWER PLANT BEING:

(A) IN AN UNANALYZED CONDITION THAT SIGNIFICANTLY COMPROMISES PLANT SAFETYJ (B) IN A CONDITION THAT IS OUTSIDE THE DESIGN BASIS OF THE PLANTJ OR (C) IN A CONDITION NOT COVERED BY THE PLANT'S OPERATING AND EMERGENCY PROCEDURES.

50 72(B)(2)(i) ANY EVENT, FOUND WHILE THE REACTOR IS SHUTDOWN, THAT, HAD IT BEEN FOUND WHILE THE REACTOR WAS IN OPERATION, WOULD HAVE RESULTED IN THE NUCLEAR POWER PLANT, INCLUDING ITS PRINCIPAL SAFETY BARRIER!

BEING SERIOUSLY DEGRADED OR BEING IN AN UNANALYZED CONDITION THAT SIGNIFICANTLY COMPROMISES PLANT SAFETY.

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c.

PARAGRAPH 50 73(A)(2)(II)

DISCUSSION "ANY EVENT OR CONDITION THAT RESULTED IN THE CONDITION OF THE NUCLEAR POWER PLANT, INCLUDING ITS PRINCIPAL SAFETY BARRIERS, BEING SERIOUSLY DEGRADED, OR THAT RESULTED IN THE NUCLEAR POWER PL ANT BEING :

(A) IN AN UNANALYZED CONDITION THAT SIGNIFICANTLY COMPROMISED PLANT SAFETY; (B) Ill A CONDITION THAT WAS OUTSIDE THE DESIGN BASIS OF THE PLANT; OR (C) IN A CONDITION NOT COVERED BY THE PLANT'S OPERATING AND EMERGENCY PROCEDURES."

INCLUDES SERIOUS DEGRADATION OF THE PLANT, INCLUDING ITS PRINCIPAL SAFETY BARRIERS, OR OPERATION IN AN UNANALYZED CONDITION.

- LICENSEE MAY USE ENGINEERING JUDGMENT AND EXPERIENCE TO DETERMINE WHETHER AN EVENT IS REPORTABLE UNDER THIS CRITERION.

- INCLUDES MATERIAL PROBLEMS THAT CAUSE ABNORMAL DEGRADATION OF THE PRINCIPAL SAFETY BARRIERS.

- EXAMPLES: - FUEL CLADDING FAILURES.

- REACTOR COOL ANT RADIOACTIVITY LEVELS THAT EXCEEDED TECHNICAL SPECIFICATION LIMITS.

! - CRACKS AND BREAKS IN PIPING, THAT HAVE SAFETY RELEVANCE.

- SIGNIFICANT WELDING OR MATERIAL DEFECTS.

l - SERIOUS TEMPERATURE OR PRESSURE TRANSIENTS.

, - LOSS OF RELIEF AND/OR SAFETY VALVE OPERABILITY.

- LOSS OF CONTAINMENT FUNCTION OR INTEGRITY.

l - DOES NOT INCLUDE MINOR VARIATIONS IN IN9IVIDUAL PARAMETERS

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PARAGRAPH S0 73(A)(2)(III)

COMPARISON OF 50 73.AND 50 72

$0 73(A)(2)(III) ANY NATURAL PHENOMENON OR OTHER EXTERNAL ~

CONDITION THAT POSED AN ACTUAL THREAT TO THE SAFETY OF THE NUCLEAR POWER PLANT OR SIGNIFICANTL HAMPERED' SITE PERSONNEL IN THE PERFORMANCE OF DUTIES NECESSARY FOR THE SAFE OPERATION OF THE NUCLEAR POWER PLANT.

50 72(a)(1)(III) ANY NATURAL PHENOMENON OR OTHER EXTERNAL CONDITION THAT POSES AN ACTUAL THREAT TO THE SAFETY OF THE NUCLEAR POWER PLANT OR SIGNIFICANTL HAMPERS SITE PERSONNEL IN THE PERFORMANCE OF DUTIES NECESSARY FOR THE SAFE OPERATION OF THE PLANT.

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PARAGRAPH S0 73(A)(2)(III)

DISCUSSION "ANY NATURAL PHENOMENON OR OTHER EXTERNAL CONDITION THAT POSED AN ACTUAL THREAT TO THE SAFETY OF THE NUCLEAR POWER PLANT OR SIGNIFICANTLY HAMPERED SITE PERSONNEL IN THE PERFORMANCE OF DUTIES NECESSARY FOR THE SAFE OPERATION OF THE NUCLEAR POWER PLANT."

INCLUDES:

- ACTS OF NATURE (E.G., TORNADOES).

- EXTERNAL HAZARDS (E.G., RAILROAD TANK CdR EXPLOSION).

- DOES NOT INCLUDE:

, - SABOTAGE (COVERED BY 573 71).

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- INTERNAL HAZARDS (E.G., RADIOACTIVITY RELEASES) (COVERED BY S0 73(A)(2)(X)].

- LICENSEE IS TO DECIDE IF A PHENOMENON OR CONDITION ACTUALLY THREATENED (1.E., " POSED AN ACTUAL THREAT") THE PLANT.

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PARAGRAPH S0 73(A)(2)(Iv)

COMPARISON OF 50 73 AND 50 72 50 73(A)(2)(Iv) ANY EVENT OR CONDITION THAT RESULTED IN MANUAL OR AUTOMATIC ACTUATION OF ANY ENGINEERED SAFETY FEATURE (ESF), INCLUDING THE REACTOR PROTECTION SYSTEM (RPS).

HOWEVER, ACTUATION OF AN ESF, INCLUDING THE RPS, THAT RESULTED FROM AND WAS PART OF THE PREPLANNED SEQUENCE DURING TESTING OR REACTOR OPERATION NEED NOT BE REPORTED.

seseeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeseeeee 50 72(a)(1)(Iv) ANY EVENT THAT RESULTS OR SHOULD HAVE RESULTED IN EMERGENCY CORE COOLING SYSTEM (ECCS) DISCHARGE INTO THE REACTOR COOLANT SYSTEM AS A RESULT OF A VALID SIGNAL.

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S0 72(a)(2)(II) ANY EVENT OR CONDITION THAT RESULTS IN MANUAL OR AUTOMATIC ACTUATION OR ANY

, ENGINEERED SAFETY FEATURE (ESF), INCLUDING l

THE REACTOR PROTECTION SYSTEM (RPS).

HOWEVER, ACTUATION OF AN ESF, INCLUDING THE RPS, THAT RESULTS FROM AND IS PART OF THE PREPLANNED SEQUENCE DURING TESTING OR REACTOR OPERATION NEED NOT BE REPORTED.

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PARAGRAPH 50 73(A)(2)(Iv)

DISCUSSION ~

"ANY EVENT OR CONDITION THAT.RES'ULTED IN MANUAL OR AUTOMAYIC ACTUATION OF ANY ENGINEERED SAFETY FEATURE (ESF), INCLUDI:4G THE REACTOR PROTECTION SYSTEM (RPS). HOWEVER, ACTUATION OF AN ESF, INCLUDING THE RPS, THAT RESULTED FROM AND WAS PART OF THE PREPL ANNED SEQUENCE DURING TESTING OR REACTOR OPERATION NEED NOT BE REPORTED."

- INCLUDES ESF ACTUATIONS EITHER MANUALLY OR AUTOMATICALLY, REGARDLESS OF PLANT STATUS.

- EVENTS WHERE AN ESF WAS NEEDED'TO MITIGATE THE CON-CONSEQUENCES.

- EVENTS WHERE AN ESF OPERATED UNNECESSARILY.

- ESF ACTUATES IN A WAY THAT IS NOT.PART OF THE PLANNED PROCEDURE.

- " ACTUATION" 0F MULTICHANNEL ESF ACTUATION SYSTEMS IS DEFINED AS ACTUATION OF ENOUGH CHANNELS TO COMPLETE THE MINIMUM ACTUATION LOGIC.

DOES NOT INCLUDE OPERATION OF AN ESF AS PART OF A PLANNED OPERATIONAL PROCEDURE OR TEST.

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- IHE FACT THAT THE SAFETY ANALYSIS ASSUMES THAT AN ESF 1 WILL ACTUATE AUTOMATICALLY DURING CERTAIN PLANT CONDITIONS l DOES NOT ELIMINATE THE NEED TO REPORT.

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., PARAGRAPHS 50 73(A)(2)(v) AND (vi)

COMPARISON OF 50 73 AND 50 72 50 73(A)(2)(v) ANY EVENT OR CONDITION THAT ALONE COULD HAVE PREVENTED THE FULFILLMENT OF THE SAFETY FUNCTION OF STRUCTURES OR SYSTEMS *THAT ARE NEEDED TO:

(A) SHUT DOWN THE REACTOR AND MA.INTAIN IT IN A SAFE SHUTDOWN CONDITION; (B) REMOV'E RESIDUAL HEATJ (C) CONTROL THE RELEASE OF RADIOACTIVE MATERIAL; OR (D) MITIGATE. THE CONSEQUENCES OF AN- ACCIDENT.

(VI) EVENTS COVERED IN PARAGRAPH (A)(2)(V) 0F THIS SECTION MAY INCLUDE ONE OR MORE PROCEDURAL ERRORS, EQUIPMENT FAILURES, AND/OR DISCOVERY OF DESIGN, ANALYSIS, FABRICATION, CONSTRUCTION, AND/OR PROCEDURAL INADEQUACIES. HOWEVER, INDIVIDUAL COMPONENT FAILURES NEED NOT BE REPORTED PURSUANT TO THIS PARAGRAPH IF REDUNDANT EQUIPMENT IN THE SAME SYSTEM WAS OPERABLE AND AVAILABLE TO PERFORM THE REQUIRED

, SAFETY FUNCTION.

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50 72(B)(2)(III) ANY EVENT OR CONDITION THAT ALONE COULD HAVE PREVENTED THE FULFILLMENT OF THE SAFETY FUNCTION OF STRUCTURES OR SYSTEMS THAT ARE NEEDED TO:

1 (A) SHUT DOWN THE REACTOR AND MAINTAIN IT IN A SAFE SHUTDOWN CONDITION, (B) REMOVE RESIDUAL HEAT, l

l (C) CONTROL THE RELEASE OF RADIOACTIVE MATERIAL, OR (D) MITIGATE THE CONSEQUENCES OF AN ACCIDENT.

. PARAGRAPHS 50 73(A)(2)(v) AND (vi) .

DISCUSSION i

"(v) ANY EVENT OR CONDITION THAT ALONE COULD HAVE PREVENTED THE FULFILLMENT OF THE SAFETY FUNCTION OF STRUCTURES OR SYSTEMS THAT ARE NEEDED To:

(A) SHUT DOWN THE REACTOR AND MAINTAIN IT IN A SAFE SHUTDOWN CONDITIONJ (B) . REMOVE RESIDUAL HEATJ (C) CONTROL THE RELEASE OF RADIOACTIVE MATERIAL; OR (D) MITIGATE THE CONSEQUENCES OF AN ACCIDENT.

(VI) EVENTS COVERED IN PARAGRAPH (A)(2)(v) 0F THIS SECTION'MAY INCLUDE ONE OR MORE PERSONNEL ERRORS, EQUIPMENT FAILURES, AND/OR DISCOVERY OF DESIGN, ANALYSIS, FABRICAf10N, CONSTRUCTION, AND/OR PROCEDURAL INADEQUACIES. HOWEVER, INDIVIDUAL COMPONENT FAILURES NEED NOT BE REPORTED PURSUANT TO THIS PARAGRAPH IF REDUNDANT EQUIPMENT IN THE SAME SYSTEM WAS OPERABLE AND AVAILABLE TO PERFORM THE REQUIRED SAFETY FUNCTION."

- INCLUDES EVENTS WHERE THERE WOULD HAVE BEEN A FAILURE OF A SAFETY SYSTEM TO PROPERLY COMPLETE A SAFETY FUNCTION, REGARDLESS OF:

- WHEN THE FAILURES WERE DISCOVERED

- WHETHER THE SYSTEM WAS NEEDED AT THE TIME-

- THE SITUATION OR CONDITION THAT CAUSED THE STRUCTURE OF SYSTEMS TO BE UNAVAILABLE,

- WHETHER AN ALTERNATE SAFETY SYSTEM COULD HAVE BEEN USED TO PERFORM THE SAFETY FUNCTION.

INCLUDES FAILURE OF SINGLE-TRAIN SYSTEMS THAT PERFORM SAFETY FUNCTIONS, IF LOSS OF THE SINGLE TRAIN WOULD PREVENT THE FULFILLMENT OF THE SAFETY FUNCTION OF THE SYSTEM-

PARAGRAPHS 50 73(A)(2)(v) AND (vi)

DISCUSSION (CONTINUED)

- INCLUDES THE FAILURE'0F TWO ~ 0R MORE TRAINS IN SAFETY SYSTEMS THAT INCLUDE THREE OR MORE TRAINS, IF THE FUNCTIONAL CAPABILITY OF THE OVERALL SYSTEM WAS JEOPARDIZED.

INCLUDES INTERACTION BETWEEN SYSTEMS, PARTICULARLY A SAFETY SYSTEM AND A NON-SAFETY SYSTEM.

- FOR EXAMPLE, A SERVICE OR INPUT WHICH IS NECESSARY FOR RELIABLE OR LONG TERM OPERATION OF A SAFETY SYSTEM IS LOST OR DEGRADED.

- INCLUDES PERSONNEL ACTIONS THAT COULD HAVE PREVENTED FULFILLMENT OF A SAFETY FUNCTION (E.G., IF THE ACTION ACTUALLY AFFECTED OR INVOLVED COMPONENTS IN MORE THAN ONE TRAIN OR CHANNEL OF A SAFETY SYSTEM).

- A TECHNICAL JUDGMENT MUST BE MADE WHETHER A FAILURE OR OPERATOR ACTION THAT DID ACTUALLY DISABLE ONE TRAIN OF A SAFETY SYSTEM, COULD HAVE, BUT DID NOT, AFFECT A REDUNDANT TF AIN WITHIN THE ESF SYSTEM.

- REPORTABLE IF THERE IS REASONABLE DOUBT THAT THE FUNCTION-ALLY REDUNDANT TRAIN OR CHANNEL WOULD REMAIN OPERATIONAL UNTIL IT COMPLETED ITS SAFETY FUNCTION OR WAS REPAIRED.

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, - , , ,.- - -, a.,. ,, - - - - -

PARAGRAPH 50 73(A)(2)(vil)

OVERVIEW 0F 50 73 AND 50 72 50173(A)(2)(VII) ANY EVENT WHERE A SINGLE CAUSE OR CONDITION .

CAUSED AT LEAST ONE INDEPENDENT TRAIN OR CHANNEL TO BECOME INOPERABLE IN MULTIPLE SYSTEMS OR TWO INDEPENDENT TRAINS OR CHANNELS TO BECOME.-INOPERABLE IN A SINGLE SYSTEM DESIGNED TO:

(A) SHUT DOWN THE REACTOR AND MAINTAIN IT IN A SAFE SHUTDOWN CONDITIONJ (B) REMOVE RESIDUAL HEATJ (C) CONTROL THE RELEASE OF RADIOACTIVE MATERIAL; OR (D) MITIGATE THE CONSEQUENCES OF AN ACCIDENT.

l 50 72 - NO COMPARABLE REQUIREMENT.

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PARAGRAPHS 50 73(A)(2)(vii)

DISCUSSION "ANY EVENT WHERE A SINGLE CAUSE OR CONDITION CAUSED AT LEAST ONE INDEPENDENT TRAIN OR CHANNEL TC BECOME INOPERABLE IN MULTIPLE SYSTEMS OR TWO INDEPENDENT TRAINS OR"*CHANNELS TO BECOME INOPERABLE IN A SYSTEM DESIGNED TO: ,-]7*

(A) SHUT DOWN THE REACTOR AND MAINTAIN IT IN A SAFE SHUTDOWN CONDITION, (B) REMOVE RESIDUAL HEAT, (C) CONTROL THE RELEASE OF RADIOACTIVE MATERIAL; OR (D) MITIGATE THE CONSEQUENCES OF AN ACCIDENT."

INCLUDES EVENTS WHERE A SINGLE CAUCE CAUSED A COMPONENT OR GROUP OF COMPONENTS TO BECOME INOPERABLE IN REDUNDANT OR INDEPENDENT PORTIONS OF ONE OR MORE SYSTEMS.

EXAMPLE: - A CAUSE OR CONDITION CAUSED COMPONENTS IN IRAIN "A" AND "B" 0F A SINGLE SYSTEM TO BECOME INOPERABLE

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REPORTABLE.

- CAUSE OR CONDITION CAUSED COMPONENTS IN IRAIN "A" 0F ONE SYSTEM AND IN IRAIN "B" 0F ANOTHER SYSTEM TO BECOME INOPERABLE = REPORTABLE.

- CAUSE OR CONDITION CAUSED COMPONENTS IN IRAIN "A" 0F ONE SYSTEM AND TRAIN "A" 0F ANOTHER SYSTEM TO BECOME INOPERABLE = NOT REPORTED.

- DOES NOT INCLUDE EVENTS WHERE A COMPONENT WAS REMOVED FROM SERVICE AS PART OF A PLANNED EVOLUTION IF:

- TECHNICAL SPECIFICATIONS PERMIT THE RESULTING CONFIGURA-TION.

- SYSTEM OR COMPONENT IS RETURNED TO SERVICE WITHIN THE TIME LIMIT SPECIFIED.

PARAGRAPHS 50 73(A)(2)(vIII) AND (IX)

COMPARISON OF S0 73 AND 50 72 50 73(A)(2)(vlII)(A) ANY AIRBORNE RADIOACTIVITY RELEASE THAT EXCEEDED 2 TIMES THE APPLICABLE CONCENTRATIONS OF THE LIMITS SPECIFIED IN APPENDIX 8, IABLE II 0F PART 20 0F THIS CHAPTER IN UNRESTRICTED AREAS, WHEN AVERAGED OVER A TIME PERIOD OF ONE HOUR.

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(B) ANY LIQUID EFFLUENT RELEASE THAT EXCEEDED 2 TIMES THE LIMITING COMBINED MAXIMUM PERMISSABLE CONCENTRATION (MPC) (SEE NOTE 1 0F APPENDIX 8 TO PART 20 0F THIS CHAPTER) AT THE POINT OF ENTRY INTO THE RECEIVING WATER (I.E., UNRESTRICTED AREA) FOR ALL RADIONUCLIDES EXCEPT TRITIUM AND DISSOLVED NOBLE GASES, WHEN AVERAGED OVER A TIME PERIOD OF ONE HOUR.

(IX) REPORTS SUBMITTED TO THE COMMISSION IN ACCORDANCE WITH PARAGRAPH ( A)(2)(vr II) 0F THIS SECTION ALSO MEET THE EFFLUENT RELEASE REPORTING REQUIREMENTS OF PARAGRAPH 20 405(A)(5) 0F PART 20 CF THIS CHAPTER.

50 72(B)(2)(Iv)(A) ANY AIRBORNE RADIOACTIVE RELEASE THAT EXCEEDS 2 TIMES THE APPLICABLE CONCENTRA-l TIONS OF THE LIMITS SPECIFIED IN APPENDIX 8,

! IABLE 11 0F PART 20 0F THIS CHAPTER IN I

' UNRESTRICTED AREAS, WHEN AVERAGED OVER A TIME PERIOD OF ONE HOUR.

(B) ANY LIQUID EFFLUENT RELEASE THAT EXCEEDS 2 TIMES THE LIMITING COMBINED MAXIMUM l PERMISSABLE CONCENTRATION (MPC) (SEE l NOTE 1 0F APPENDIX 8 TO PART 20 0F THIS i

CHAPTER) AT THE POINT OF ENTRY INTO THE

! RECEIVING WATER (I.E., UNRESTRICTED l

AREA) FOR ALL RADIONUCLIDES EXCEPT I TRITIUM AND DISSOLVED NOBLE GASES, WHEN AVERAGED OVER A TIME PERIOD OF ONE HOUR-l (lMMEDIATE NOTIFICATIONS MADE UNDER THIS PARAGRAPH ALSO SATISFY THE REQUIREMENTS OF PARAGRAPHS (A)(2) AND (B)(2) 0F 520 403 0F PART 20 0F THIS CHAPTER.)

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PARAGRAPHS 50 73( A)(2)(vi!I) AND (1x)

DISCUSSION

"(VIII)(A) ANY AIRBORNE RADIOACTIVITY RELEASE THAT EXCEEDED 2 TIMES THE APPLICABLE

.C g ENTRATIONS OF THE LIMITS SPECIFIED

'ik lABLE 11 0F APPENDIX B TO PART 20 0F THIS CHAPTER IN UNRESTRICTED AREAS, WHEN AVERAGED OVER A TIME PERIOD OF ONE HOUR.

(B) ANY LIQUID EFFLUENT RELEASE THAT' EXCEEDED 2 TIMES THE LIMITING COMBINED MAXIMUM PERMISSIBLE CONCENTRATION (MPC) (SEE NOTE 1 0F APPENDIX B TO PART 20 0F THIS CHAPTER) AT THE POINT OF ENTRY INTO THE RECEIVING WATER (I.E. , UNRESTRICTED AREA)

FOR ALL RADIONUCLIDES EXCEPT TRITIUM AND DISSOLVED NOBLE GASES, WHEN AVERAGED OVER A TIME PERIOD OF ONE HOUR.

1 (IX) REPORTS SUBMITTED TO THE COMMISSION IN ACCORDANCE WITH PARAGRAPHS (A)(2)(vlII) 0F THIS SECTION ALSO MEET THE EFFLUENT RELEASE REPORTING REQUIREMENTS OF PARAGRAPH 20 405(A)(5) 0F PART 20 0F THIS CHAPTER."

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THE REQUIREMENT IS SIMILAR TO 520 405 BUT PLACES A LOWER

! THRESHOLD FOR REPORTING EVENTS AT COMMERCIAL POWER REACTORS BECAUSE OF THE SIGNIFICANCE OF THE BREAKDOWN OF THE LICENSEE'S PROGRAM NECESSARY TO HAVE A RELEASE OF THIS MAGNITUDE.

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! - REPORT IN LIEU OF REPORTING NOBLE GAS RELEASES THAT l

EXCEEDED 10 TIMES THE INSTANTANEOUS RELEASE RATE REQUIRED BY 520 405(A)(5).

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PARAGRAPH 50 73(A)(2)(x)

COMPARISON OF 50 73 AND S0 72 50 73(A)(2)(x) ANY EVENT THAT POSED AN ACTUAL THREAT TO THE SAFETY OF THE NUCLEAR POWER PLANT OR SIGNIFICANTLY HAMPERED SITE PERSONNEL IN THE PERFORMANCE OF

. DUTIES NECESSARY FOR THE SAFE OPERATION OF THE NUCLEAR POWER PLANT INCLUDING FIRES, T0XIC GAS RELEASES, OR RADIOACTIVE RELEASES.

$0 72(B)(1)(VI) ANY EVENT THAT POSES AN ACTUAL THREAT TO THE SAFETY OF THE NUCLEAR POWER PLANT OR SIGNIFICANTLY HAMPERS SITE PERSONNEL IN THE PERFORMANCE OF DUTIES NECESSARY FOR THE SAFE OPERATION OF THE NUCLEAR POWER PLANT INCLUDING FIRES, T0XIC GAS RELEASES, OR RADIOACTIVE RELEASES.

PARAGRAPH 50 73(A)(2)(x)

DISCUSSION "ANY EVENT THAT POSED AN ACTUAL THREAT TO THE SAFETY OF THE NUCLEAR POWER PLANT OR SIGNIFICANTLY HAMPERED SITE PERSONNEL IN THE PERFORMANCE OF DUTIES NECESSARY FOR THE SAFE OPERATION OF THE NUCLEAR POWER PLANT INCLUDING FIRES, T0XIC GAS RELEASES, OR RADIOACTIVITY RELEASES."

INCLUDES PHYSICAL HAZARDS INTERNAL TO THE PLANT.

j - HAZARD MUST HAMPER THE ABILITY OF SITE PERSONNEL TO PERFORM SAFETY-RELATED ACTIVITIES.

i - LICENSEE IS TO DECIDE IF AN EVENT POSED AN ACTUAL THREAT TO THE PLANT OR SIGNIFICANTLY HAMPERED SITE PERSONNEL.

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COMPARISON OF 50.'73 AND 50 72 50 73 - NO COMPARABLE REQUIREMENT.

50 72(B)(1)(v) ANY EVENT THAT RESULTS IN A MAJOR LOSS OF EMERGENCY ASSESSMENT CAPABILITY, OFFSITE RESPONSE CAPABILITY, OR COMMUNICATIONS CAPABILITY (E.G., SIGNIFICANT PORTION OF CONTROL ROOM INDICATION, EMERGENCY NOTIFICA-TION SYSTEM, OR OFFSITE NOTIFICATION SYSTEM).

50 72(B)(2)(v) ANY EVENT REQtlIRING THE TRANSPORT OF A RADIOACTIVITY CONTAMINATED PERSON TO AN OFFSITE MEDICAL FACILITY FOR TREATMENT.

50 72(B)(2)(vi) ANY EVENT OR SITUATION, RELATED TO THE HEALTH AND SAFETY OF THE PUBLIC OR ONSITE PERSONNEL, OR PROTECTION OF THE ENVIRONMENT, FOR WHICH A NEWS RELEASE IS PLANNED OR NOTIFICATION TO OTHER GOVERN-MENT AGENCIES HAS BEEN OR WILL BE MADE.

SuCH AN EVENT MAY INCLUDE AN ONSITE FATALITY OR INADVERTENT RELEASE OF RADIOACTIVE CONTAMINATED MATERIALS.

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IMPACT On RELATED REPORTING REQUIREMENTS FREDERICK J. HEBDON, CHIEF, PROGRAM IECHNOLOGY BRANCH, OFFICE FOR ANALYSIS AND EVALUATION OF OPERATIONAL DATA 4

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10 CFR PART 20 STANDARDS FOR PROTECTION AGAINST RADIATION 520 402 REPORTS OF THEFT OR LOSS OF LICENSED MATERIAL IN 520 402, PARAGRAPH (A) HAS BEEN REVISED) THE INTRODUCTORY TEXT OF PARAGRAPH (B) HAS BEEN REVISEDj AND A HEW PARAGRAPH (E) HAS BEEN ADDED TO READ AS FOLLOWS:

(A)(1) EACH LICENSEE SHALL REPORT TO THE COMMISSION, BY TELEPHONE, IMMEDIATELY AFTER IT DETERMINES THAT A LOSS OR THEFT OF SUCH CIRCUMSTANCES THAT IT APPEARS TO THE LICENSEE THAT.A SUBSTANTIAL HAZARD MAY RESULT

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TO PERSONS IN UNRESTRICTED AREAS.

(2) REPORTS MUST BE MADE AS FOLLOWS:

(I) l!CENSEES HAVING AN INSTALLED. EMERGENCY NOTIFICA-TION SYSTEM SHALL MAKE THE REPORTS TO THE NRC OPERATIONS CENTER IN ACCORDANCE WITH 550 72 0F THIS CHAPTER.

(II) ALL OTHER LICENSEES SHALL MAKE REPORTS TO THE ADMINISTRATOR OF THE APPROPRIATE NRC REGIONAL OFFICE LISTED IN APPENDIX D OF THIS PART.

l l (B) EACH LICENSEE WHO MAKES A REPORT UNDER PARAGRAPH (A) 0F THIS SECTION SHALL, WITHIN 30 DAYS AFTER LEARNING OF THE LOSS OR THEFT, MAKE A REPORT IN WRITING TO THE U.S.

NUCLEAR REGULATORY COMMISSION, DOCUMENT CONTROL DESK, WASHINGTON, D.C. 205S5, WITH A COPY TO THE APPROPRIATE NRC REGIONAL OFFICE LISTED IN APPENDIX 0 0F THIS PART.

THE REPORT SHALL INCLUDE THE FOLLOWING INFORMATION:

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520 402 REPORTS OF THEFT OR LOSS OF LICENSED MATERIAL (CONTINUED)

(E) FOR HOLDERS OF AN OPERATING LICENSE FOR A NUCLEAR POWER PLANT, THE EVENTS INCLUDED IN PARAGRAPH '(B) 0F THIS SECTION MUST BE REPORTED IN ACCORDANCE WITH THE PROCEDURES DESCRIBED IN PARAGRAPHS S0 73(s), (C), (D), (E), AND (G) 0F THIS CHAPTER AND MUST INCLUDE THE INFORMATION REQUIRED IN PARAGRAPH (B) 0F THIS SECTION. EVENTS REPORTED IN ACCORDANCE WITH 550 73 OF THIS CHAPTER NEED NOT BE REPORTED BY A DUPLICATE REPORT UNDER PARAGRAPH (B) 0F THIS SECTION.

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520 403 NOTIFICATION OF INCIDENTS IN 520 403, THE INTRODUCTORY TEXT OF PARAGRAPHS (A) AND (B)

HAVE BEEN REVISED, AND PARAGRAPH (D) HAS BEEN REVISED TO READ AS FOLLOWS:

(A) IMMEDIATE NOTIFICATION. EACH LICENSEE SHALL IMMED I'ATELY REPORT ANY EVENTS INVOLVING BYPRODUCT, SOURCE,.OR SPECIAL NUCLEAR MATERIAL POSSESSED BY THE LICENSEE THAT.MAY HAVE CAUSED OR-THREATENS TO CAUSE:

(B) IWENTY-FOUR HOUR NOTIFICATIOg. EACH LICENSEE SHALL WITHIN 24 HOURS OF DISCOVERY OF THE EVENT, REPORT ANY EVENT INVOLVING LICENSED MATERIAL POSSESSED BY THE LICENSEE THAT MAY HAVE CAUSED OR THREATENS TO CAUSE:

(D) REPORTS MADE BY LICENSEES IN RESPONSE TO THE. REQUIREMENTS OF THIS SECTION MUST BE MADE AS FOLLOWS:

(1) LICENSEES THAT HAVE AN INSTALLED EMERGENCY NOTIFICATION SYSTEM SHALL MAKE THE REPORTS REQUIRED BY PARAGRAPHS (A)

AND (B) 0F THIS SECTION TO THE NRC OPERATIONS CENTER IN ACCORDANCE WITH 550 72 0F THIS CHAPTER.

(2) ALL OTHER LICENSEES SHALL MAKE THE REPORTS REQUIRED BY PARAGRAPHS ( A) AND (B) 0F THIS SECTION BY TELEPHONE AND BY TELEGRAM, MAILGRAM, OR FACSIMILE TO THE ADMINISTRATOR OF THE APPROPRIATE NRC REGIONAL OFFICE LISTED IN APPENDIX OF THIS PART.

520 405 REPORTS OF OVEREXPOSURES AND EXCESSIVE LEVELS AND CONCENTRATIONS IN S20 405, PARAGRAPHS (A) AND (C) HAVE BEEN REVISED, AND A NEW PARAGRAPH (D) HAS BEEN ADDED TO READ AS FOLLOWS:

(A)(1) IN ADDITION TO ANY NOTIFICATION REQUIRED BY S20 403 0F THIS PART, EACH LICENSEE SHALL MAKE A REPORT IN WRITING CONCERNING ANY ONE OF THE FOLLOWING TYPES OF INCIDENTS WITHIN 30 DAYS OF ITS OCCURRENCE:

(I) EACH EXPOSURE OF AN INDIVIDUAL TO RADIATION IN EXCESS OF THE APPLICABLE LIMITS IN 5520 101 OR 20 104(A) 0F THIS PART, OR THE LICENSEJ (II) EACH EXPOSURE OF AN INDIVIDUAL TO RADIOACTIVE MATERIAL IN EXCESS OF THE APPLICABLE LIMITS IN SS20 103(A)(1), 20 103(A)(2), OR 20 104(B)

OF THIS PART, OR IN THE LICENSE; (III) LEVELS OF RADIATION OR CONCENTRATIONS OF RADIOACTIVE MATERIAL IN A RESTRICTED AREA IN EXCESS OF ANY OTHER APPLICABLE LIMIT IN THE LICENSE; l

(IV) ANY INCIDENT FOR WHICH NOTIFICATION IS REQUIRED BY S20 403 0F THIS PART; OR (V) LEVELS OF RADIATION OR CONCENTRATIONS OF RADIO-l ACTIVE MATERIAL (WHETHER OR NOT INVOLVING EXCESSIVE EXPOSURE OF ANY INDIVIDUAL) IN AN UNRESTRICTED AREA IN EXCESS OF TEN TIMES ANY APPLICABLE LIMIT SET FORTH IN THIS PART OR IN THE LICENSE.

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520 405 REPORTS OF OVEREXPOSURES AND EXCESSIVE LEVELS AND CONCENTRATIONS (CONTINUED)

(2) EACH REPORT REQUIRED UNDER PARAGRAPH (A)(1) 0F THIS i

SECTION MUST DESCRIBE THE EXTENT OF EXPOSURE OF INDIVIDUALS TO RADIATION OR TO RADIOACTIVE MATERIAL, INCLUDING (I) ESTIMATES OF EACH INDIVIDUAL'S EXPOSURE AS REQUIRED BY PARAGRAPH (B) 0F THIS SECTIONJ (II) LEVELS OF RADIATION AND CONCENTRATIONS OF RADIOACTIVE MATERIAL INVOLVEDJ (III) THE CAUSE OF THE EXPOSURE, LEVELS, OR CONCENTRATIONSJ AND (IV) CORRECTIVE STEPS TAKEN OR PLANNED TO PREVENT A RECURRENCE.

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'(C)(1) IN" ADDITION TO ANY NOTIFICATION REQUIRED BY S20 403 0F THIS PART, EACH LICENSEE SHALL MAKE A REPORT IN WRITING OF LEVELS OF RADIATION OR RELEASES OF RADIOACTIVE MATERIAL IN EXCESS OF LIMITS SPECIFIED BY 40 CFR PART 190, " ENVIRON-MENTAL RADIATION PROTECTION STANDARDS FOR NUCLEAR POWER OPERATIONS," OR IN EXCESS OF LICENSE CONDITIONS RELATED TO COMPLI ANCE WITH 40 -CFR PART 190 (2) EACH REPORT SUBMITTED UNDER PARAGRAPH (C)(1) 0F THIS SECTION MUST DESCRIBE:

(I) THE EXTENT OF EXPOSURE OF INDIVIDUALS TO RADIATION OR TO RADIOACTIVE MATERIALJ (II) LEVELS OF RADIATION AND CONCENTRATIONS OF RADIOACTIVE MATERIAL INVOLVEDJ (III) THE CAUSE OF THE EXPOSURE, LEVELS, OR CONCENTRATIONSJ AND l (IV) CORRECTIVE STEPS TAKEN OR PLANNED TO ASSURE AGAINST I A RECURRENCE, INCLUDING THE SCHEDULE FOR ACHIEVING CONFORMANCE WITH 40 CFR PART 190 AND WITH ASSOCIATED LICENSE CONDITIONS.

(D) FOR HOLDERS OF AN OPERATING LICENSE FOR A NUCLEAR POWER PLANT, THE INCIDENTS INCLUDED IN PARAGRAPHS (A) OR (C) 0F THIS SECTION MUST BE REPORTED IN ACCORDANCE WITH THE PROCEDURES DESCRIBED IN PARAGRAPHS S0 73(B), (C), (D), (E), AND (G) 0F THIS CHAPTER AND MUST ALSO INCLUDE THE INFORMATION REQUIRED BY PARAGRAPHS (A) AND (C) 0F THIS SECTION. INCIDENTS REPORTED IN ACCORDANCE WITH 550 73 0F THIS CHAPTER ~NEED NOT BE REPORTED BY A DUPL ICATE REPORT UNDER PARAGRAPHS ( A) OR (C) 0F THIS SECTION.

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10 CFR- PART 21 REPORTING 0F D5FECTS AND NONCOMPLIANCES COMPLETE REVISION OF PART 21 IS CURRENTLY' IN PROGRESS.

THE REVISED REPORTING REQUIREMENTS WILL BE CONSISTENT WITH 10 CFR 50 72 AND 10 CFR 50 73 9

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.d 10 CFR PART 50 DOMESTIC LICENSING 0F PRODUCTION AND UTILIZATION FACILITIES 550 36 TECHNICAL SPECIFICATIONS IN PARAGRAPH ( C .) 0F 550 36, NEW PARAGRAPHS'(6) AND (7) HAVE BEEN ADDED TO RIAD AS FOLLOWS:

(C) (6) INITIAL NOTIFICATION. REPORTS MADE T0'THE COMMISSION BY LICENSEES IN RESPONSE TO THE REQUIREMENTS OF THIS SECTION MUS'T BE MADE AS FOLLOWS:

(I) LICENSEES THAT HAVE'AN INSTALLED EMERGENCY NOTIFICATION SYSTEM SHALL MAKE THE INITIAL NOTIFICATION TO THE NRC OPERATIONS CENTER IN ACCORDANCE WITH 550 72 0F THIS PART.

.e (II) ALL OTHER' LICENSEES SHALL MAKE THE INITIAL NOTIFICATION BY TELEPHONE TO THE ADMINISTRATOR OF THE APPROPRIATE NRC REGIONAL OFFICE LISTED IN APPENDIX D, PART 20, OF THIS CHAPTER.

(7) WRITTEN REPORTS. HOLDERS OF AN OPERATING LICENSE FOR i A NUCLEAR POWER. PLANT SHALL SUBMIT A WRITTEN REPORT TO THE COMMISSION CONCERNING THE INCIDENTS INCLUDED IN PARAGRAPHS (C)(1) AND (2) 0F THIS SECTION IN ACCORDANCE WITH THE PROCEDURES DESCRIBED IN PARAGRAPHS 50 73(s),

(C), (D), (E), AND (G) 0F THIS PART. INCIDENTS REPORTED IN ACCORDANCE WITH 50 73 0F THIS PART NEED NOT ALSO BE j REPORTED UNDER PARAGRAPHS (C)(1) OR (2) 0F THIS SECTION.

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550 55(E) CONDITIONS OF CONSTRUCTION PERMITS COMPLETE REVISION OF 10 CFR 50 55(E) IS CURRENTLY IN PROGRESS.

- THE REVISED REPORTING REQUIREMENTS WILL BE CONSISTENT WITH 10 CFR 50 72 AND 10 CFR 50 73 f

10 CFR PART 73 PHYSICAL PROTECTION OF PLANTS .AND MATERIALS 573 73 REPORTS OF UNACCOUNTED-FOR SHIPMENTS, SUSPECTED THEFTS, UNLAWFUL DIVERSION, RADIOLOGICAL SABOTAGE, OR EVENTS WHICH SIGNIFICANTLY THREATEN OR LESSEN THE EFFECTIVENESS OF SAFEGUARDS

- COMPLETE REVISION OF 10 CFR 73 71 IS CURRENTLY IN PROGRESS.

- THE REVISED REPORTING REQUIREMENTS WILL BE CONSISTENT WITH 10 CFR 50 72 AND 10 CFR 50 73 l

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t CONTENT.0F THE.LER FREDERICK J. HEBDON g CHIEF, PROGRAM TECHNOLOGY DRANCH, 0FFICE FOR ANALYSIS AND EVALUATION OF OPERATIONAL DATA a

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CONTENT OF THE LER

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50 73(B) THE l!CENSEE EVENT REPORT SHALL CONTAIN:

- 50 73(B)(1) A BRIEF ABSTRACT.

- MAJOR-0CCURRENCES.

- ALL COMPONENT FAILURES.

l. - SIGNIFICANT CORRECTIVE ACTION.

- THE ABSTRACT SHOULD BE NO MORE THAN 1400 TYPEWRITTEN CHARACTERS.

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CONTENT OF THE LER (CONTINUED)

- 50 73(s)(2)(I) A CLEAR, SPECIFIC, NARRATIVE DESCRIPTION OF WHAT OCCURRED SO THAT KNOWLEDGEABLE READERS CONVERSANT WITH THE DESIGN OF COMMERCIAL NUCLEAR POWER PLANTS, BUT NOT FAMILLIAR WITH THE DETAILS OF.A PARTICULAR PLANT, CAN UNDERSTAND THE COMPLETE EVENT.

- EMPHASIZE HOW SYSTEMS, COMPONENTS, AND OPERATING PERSONNEL PERFORMED.

- DESCRIBE CHARACTERISTICS OF A PLANT THAT ARE UNIQUE AND THAT INFLUENCED THE EVENT.

- DESCRIBE THE EVENT FROM THE PERSPECTIVE OF THE OPERATOR.

- DO NOT COVER SPECIFIC HARDWARE PROBLEMS IN EXCESSIVE DETAIL.

- DO NOT USE TERMS, INITIALS, OR ACRONYMS THAT ARE ONLY IN LOCAL USE.

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CONTENT OF THE LER (CONTINUED)

- 50 73(B)(2)(II) THE NARRATIVE DESCRIPTION MUST INCLUDE THE FOLLOWING SPECIFIC'INFORMATION AS APPROPRIATE FOR THE PARTICULAR EVENT:

(A) PLANT OPERATING CONDITIONS BEFORE THE EVENT.

(B) STATUS OF STRUCTURES, COMPONENTS, OR SYSTEMS THAT WERE INOPERABLE AT THE START OF THE EVENT AND THAT CONTRIBUTED TO THE EVENT.

(C) DATES AND APPROXIMATE TIMES OF OCCURRENCES.

(D) THE CAUSE OF EACH COMPONENT OR SYSTEM FAILURE OR PERSONNEL ERROR, IF KNOWN.

(E) THE FAILURE MODE, MECHANISli, AND EFFECT OF EACH FAILED COMPONENT, IF KNOWN.

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CONTENT OF THE LER (CONTINUED)

(F) THE ENERGY INDUSTRY IDENTIFICATION SYSTEM COMPONENT FUNCTION IDENTIFIER AND SYSTEM NAME OF EACH COMPONENT OR SYSTEM REFERRED TO IN THE LER.

- DEFINED IN IEEE STDS 803-1983, 803A-1983, AND 805-1983

" SYSTEM NAME" MAY BE EITHER THE FULL NAME (E.G.,

REACTOR COOLANT SYSTEM) OR THE TWO LETTER SYSTEM CODE (E.G., AB).

- WHEN THE NAME IS LONG THE CODE SHOULD BE USED.

INCLUDE THE NAME AND/OR CODES IN PARENTHESIS FOLLOWING THE FIRST REFERENCE TO A SYSTEM OR COMPONENT IN THE TEXT OF THE LER.

- THE NAME AND/OR CODE NEED NOT BE REPEATED WITH EACH SUBSEQUENCE REFERENCE TO THE SAME COMPONENT OR SYSTEM.

- 00 NOT INCLUDE THE PARENTHETICAL NAMES OR CODES IN THE ABSTRACT SECTION.

- INTERPRETATION OF A SYSTEM BOUNDARY SHOULD BE CONSISTENT WITH THE COMPARABLE SYSTEM DESCRIPTIONS AND INTERPRETATIONS CONTAINED IN THE NPRDS REPORTABLE SYSTEM AND COMPONENT MANUAL.

CONTENT OF THE LER (CONTINUED)

(G) A LIST OF SYSTEMS OR SECONDARY FUNCTIONS THAT WERE ALSO AFFECTED.

(H) FOR FAILLRE THAT RENDERED A TRAIN OF A SAFETY SYSTEM INOPERABLE, AN ESTIMATE OF'THE ELAPSED TIME FROM THE DISCOVERY OF THE FAILURE UNTIL THE TRAIN WAS RETURNED TO SERVICE.

(I) THE METHOD OF DISCOVERY OF EACH COMPONENT OR SYSTEM FAILURE OR PROCEDURAL ERROR.

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CONTENT OF THE LER (CONTINUED)

(J)(1) OPERATOR ACTIONS THAT AFFECTED THE COURSE OF THE EVENT, (2) FOR EACH PERSONNEL ERROR.

- COGNITIVE ERROR.

- ACTION CONTRARY TO AN' APPROVED PROCEDURE.

i

- ACTION THAT WAS A DIRECT RESULT OF AN ERROR IN AN APPROVED PROCEDURE.

- ACTION NOT COVERED BY AN APPROVED PROCEDURE.

- UNUSUAL CHARACTERISTICS OF THE WORK LOCATION.

- TYPE OF PERSONNEL INVOLVED.

(K) AUTOMATICALLY AND MANUALLY INITIATED SAFETY SYSTEM RESPONSES-(L) THE MANUFACTURER AND MODEL NUMBER OF EACH COMPONENT THAT FAILED.

CONTENT OF THE LER (CONTINUED)

- 50 73(a)(3) AN ASSESSMENT OF THE SAFETY CONSEQUENCES AND IMPLICATIONS OF THE EVENT.

INCLUDE THE AVAILABILITY OF OTHER SYSTEMS OR COMPONENTS THAT COULD HAVE PERFORMED THE SAME FUNCTION.

- BASED ON THE CONDITIONS EXISTING AT THE TIME OF THE EVENT.

- ASSESSMENT OF THE EVENT UNDER ALTERNATIVE CONDITIONS MUST BE INCLUDED IF THE INCIDENT WOULD HAVE BEEN MORE SEVERE UNDER REASONABLE AND CREDIBLE ALTERNATIVE CONDITIONS.

- 50 73(B)(4) A DESCRIPTION OF ANY CORRECTIVE ACTIONS.

- DESCRIBE CORRECTIVE ACTIONS ON SIMILAR OR RELATED COMPONENTS THAT WERE DONE AS A DIRECT RESULT OF THE EVENT.

- DISCUSS WHY PRIOR CORRECTIVE ACTION DID NOT PREVENT RECURRENCE.

- ONLY SUBSTANTIAL CHANGES IN THE CORRECTIVE ACTION NEED BE REPORTED AS A SUPPLEMENTAL LER.

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50 73(B)(5) REFERENCE TO ANY PREVIOUS SIMILAR EVENTS.

- 50 73(B)(6) THE NAME AND TELEPHONE NUMBER OF A CONTACT.

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9 LER REPORT PREPARATION AND SUBMISSION FREDERICK J. HEBDON g CHIEF, PROGRAM IECHNOLOGY DRANCH, 0FFICE FOR ANALYSIS AND EVALUATION OF OPERATIONAL DATA i

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INSTRUCTIONS FOR COMPLETING THE LER FORMS GENERAL INSTRUCTIONS

- ERRORS DISCOVERED IN AN LER SHOULD BE CORRECTED IN A REVISED REPORT.

- THE REVISED REPORT SHOULD BE A COMPLETE ENTITY AND NOT CONTAIN ONLY SUPPLEMENTARY OR REVISED INFORMATION.

- A REVISION SHOULD NOT BE USED TO REPORT SUBSEQUENT FAILURES OF THE SAME OR LIKE COMPONENTS.

- ONLY SUBSTANTIAL INFORMATION THAT WOULD SIGNIFICANTLY CHANGE A READER'S PERCEPTION OF THE COURSE OR CONSEQUENCES OF AN EVENT, OR SUBSTANTIAL CHANGES IN THE CORRECTIVE ACTION PLANNED BY THE LICENSEE NEED BE REPORTED IN A REVISED LER.

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INSTRUCTIONS FOR COMPLETING THE LER FORM SPECIFIC INSTRUCTIONS ITEM 1: FACILITY NAME IF THE EVENT INVOLVED MORE THAN ONE UNIT AT A STATION, ENTER THE NAME OF THE LOWEST NUMBERED NUCLEAR UNIT.

ITEM 2: DOCKET NUMBER l

ITEM 3: PAGE NUMBER 1 TEM 4: EVENT TITLE

, - CONCISE DESCRIPTION OF THE EVENT WHICH DEFINES THE PRINCIPAL PROBLEM OR ISSUE ASSOCIATED WITH THE EVENT.

" LICENSEE EVENT REPORT" SHOULD NOT BE USED.

ITEM 5: EVENT DATE

- MMDDYY FORMAT

INSTRUCTIONS FOR COMPLETING THE LER FORM

("0NTINUED)

ITEM 6: REPORT NUMBER

- EVENT YEAR.

- BASED ON EVENT DATE, NOT REPORT DATE.

SEQUENTIAL REPORT NUMBER.

- EACH NUCLEAR UNIT SHOULD.HAVE ITS~OWN SET OF SEQUENTIAL REPORTS NUMBERS.

- BEGIN WITH 001 FOR THE FIRST EVENT THAT OCCURRED IN EACH CALENDAR YEAR.

- FOR EVENTS COMMON TO MORE THAN ONE UNIT OF A MULTIPLE UNIT SITE, ASSIGN THE SEQUENTIAL NUMBER FOR THE LOWEST NUMBERED NUCLEAR UNIT.

- IF THE SQUENTIAL NUMBER IS ASSIGNED TO AN EVENT, AND IT IS SUBSEQUENTLY DETERMINED THAT THE EVENT IS NOT REPORTABLE, WRITE A BRIEF LETTER TO THE NRC NOTING THAT "LER . U'iBER XXX FOR DOCKET 05000YYY WILL

.NOT BE USED."

- REVISION NUMBER.

^

INSTRUCTIONS FOR COMPLETING THE LER FORM

-(CONTINUED)

ITEM 7: REPORT DATE ITEM 8: OTHER FACILITIES l ITEM 9: OPERATING MODE

- AS DEFINED IN THE PLANT'S TECHNICAL SPECIFICATIONS.

- IF IECHNICAL SPECIFICATIONS DO NOT SPECIFICALLY DEFINE OPERATING MODES, THE LETTER "N" SHOULD BE ENTERED.

ITEM 10: POWER LEVEL

INSTRUCTIONS FOR COMPLETING THE LER FORM (CONTINUED) l_ TEM 11: REPORTING REQUIREMENTS

- CHECK ONE OR MORE BLOCKS DEPENDING ON THE REPORTING REQUIRE-MENTS THAT WERE MET BY THE EVENT.

- A SINGLE EVENT CAN MEET MORE THAN ONE REPORTING CRITERIA.

- FOR' EXAMPLE:

IF AS A RESULT OF SABOTAGE (REPORTABLE UNDER 573 71(B)] A SAFETY SYSTEM FAILED TO FUNCTION (REPORTABLE UNDER 550 73(A)(2)(v)] AND THE NET RESULT WAS A RELEASE OF RADIOACTIVE MATERIAL IN A RESTRICTED AREA THAT EXCEEDED THE APPLICABLE LICENSE LIMIT (REPORTABLE UNDER 520 405(A)(1)(Ill)}.

- CHECK 573 71(B), 50 73(A)(2)(v), AND 520 405 (A)(1)(Ill).

- AN EVENT CAN BE REPORTED AS AN LER EVEN IF IT DOES NOT MEET ANY OF THE SPECIFIC CRITERIA IN 50 73 4

"0THER" BLOCK SHOULD BE USED IF A REPORTING REQUIREMENT IS MET THAT IS NOT SPECIFIED IN ITEM 11 FOR EXAMPLE, AN OPTIONAL REPORT OF AN UNUSUAL EVENT.

ITEM 12: LICENSEE CONTACT

INSTRUCTIONS FOR COMPLETING THE LER FORM (CONTINUED)

ITEM 13: COMPONENT FAILURES

- FAILURE IS DEFINED AS THE TERMINATION OF THE ABILITY OF AN ITEM TO PERFORM ITS REQUIRED FUNCTION.

- INCLUDES COMPLETE AND DEGRADED FAILURES.

- FOR MULTIPLE FAILURES ONLY A SINGLE ENTRY IS REQUIRED IN ITEM 13

- CAUSE: THE ROOT CAUSE OF THE FAILURE FROM APPENDIX B 0F NUREG-1022

- SYSTEM: FROM IEEE STANDARD 805-1983

- COMPONENT: FROM IEEE STANDARD 803A-1983

- COMPONENT MANUFACTURER:

- FROM THE NPRDS REPORTING PROCEDURES MANUAL.

- MANUFACTURERS THAT ARE NOT INCLUDED IN THE LIST SHOULD BE DESIGNATED X999

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- REPORTABLE TO NPRDS: "Y" OR "N".

- ADDITIONAL , COMPONENT FAILURES MAY BE CODED ON ONE OR MORE FAILURE CONTINUATION SHEETS (NRC-366B).

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INSTRUCTIONS FOR COMPLETING THE LER FORM (CONTINUED)

ITEM 14: SUPPLEMENTAL REPORT ITEM 15: EXPECTED SUBMISSION DATE OF SUPPLEMENTAL REPORT ITEM 16: ABSTRACT

- THE ABSTRACT SHOULD BE LIMITED TO 1400 CHARACTERS (INCLUDING SPACES).

ITEM 17: IEXT

- NO PRESCRIBED FORMAT FOR THE LER TEXT.

- WRITTEN IN THE FORMAT THAT MOST CLEARLY DESCRIBES THE EVENT.

- 50 73(B) IS NOT INTENDED AS AN OUTLINE OF THE TEXT FORMAT.

i 50 73(B) SHOULD BE REVIEWED TO INSURE THAT APPLICABLE SUBJECT i

HAVE BEEN ADEQUATELY ADDRESSED IN THE TEXT.

THE TEXT MAY BE CONTINUED ON.ONE OR MORE IEXT CONTINUATION SHEETS (NRC-366A).

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ADMINISTRATIVE REQUIREMENTS

- 50 73(C) THE COMMISSION MAY REQUIRE THE LICENSEE TO SUBMIT SPECIFIC ADDITIONAL INFORMATION.

- 50 73(D) - AN LER MUST BE-SUBMITTED WITHIN 30 DAYS OF DISCOVERY.

- THE LER SHOULD BE SENT TO THE U.S. NUCLEAR REGULATORY COMP!SSION t DOCUMENT CONTROL DESK, WASHINGTON, D.L. 20555; WITH A COPY TO THE APPROPRIATE NRC REGIONAL OFFICE.

- 50 73(E) IHE LER MUST BE OF SUFFICIENT QUALITY TO PERMIT LEGIBLE REPRODUCTION AND MICR0 GRAPHIC PROCESSING.

- 50 73(F) UPON WRITTEN REQUEST FROM A LICENSEE INCLUDING ADEQUATE JUSTIFICATION OR AT THE INITIATION OF THE NRC STAFF, THE NRC EXECUTIVE DIRECTOR FOR OPERATIONS MAY, BY A LETTER TO THE LICENSEE, GRANT EXEMPTIONS.

- 50 73(G) 50 73 REPL ACE (S) ALL EXISTING REQUIREMENTS FOR LICENSEES TO REPORT " REPORTABLE OCCURRENCES" AS DEFINED IN INDIVIDUAL PL ANT IECHNICAL SPECIFICATIONS.

- USUALLY TITLED " PROMPT NOTtFICATION WITH WRITTEN FOLLOWUP" (SECTION 6 9 1 8) AND " THIRTY DAY WRITTEN REPORTS" (SECTION 6 9 1 9).

- THE DISCUSSION OF LER REPORTING IN REGULATORY GUIDE 1 16 AND THE INSTRUCTIONS FOR COMPLETING THE EXISTING LER Fors..d IN NUREG-0161 SHOULD NOT BE USED AFTER JANUARY 1, 1984

s 4

NRC REGIONAL fiEETING ON THE LICENSEE EVENT REPORT SYSTEM INTRODUCTION C. J. HELTEMES, DIRECTOR OFFICE FOR ANALYSIS AND EVALUATION {

OF OPERATIONAL DATA

(

OCTOBER 26, 1983 Fosg-gG-7zy 9

4 MEETING TOPICS

- MONITORING FOR CONSISTENT INTERPRETATION AND IMPLEMENTATION.

i

- ENFORCEMENT'0F LER REPORTING REQUIREMENTS.

- QUALITY OF REPORTING AND IMPACT ON LER REVIEW PROGRAMS.

- ENGINEERING JUDGMENT IN IDENTIFYING REPORTABLE EVENTS.

- REGIONAL COMMENTS ON THE LER SYSTEM, PARTICULARLY NUREG-1022,

" LICENSEE EVENT REPORT SYSTEM."

SELECTED TOPICS FROM THE LER RULE

- NARRATIVE FORMAT

- ENERGY INDUSTRY IDENTIFICATION SYSTEM

- EXEMPTIONS

- REPLACEMENT OF EXISTING IECHNICAL $PECIFICATION REPORTING REQUIREMENTS 4

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NUREG-1022, LICENSEE EVENT REPORT SYSTEM CONTENTS:

- THE LER RULE.

4

- A BRIEF DESCRIPTION OF HOW LERS ARE ANALYZED BY

THE NRC.

- A RESTATEMENT OF THE GUIDANCE CONTAINED IN THE STATEMENT'0F CONSIDERATION THAT ACCOMPANIED THE PUBLICATION OF THE LER RULE.

- GENERAL AND SPECIFIC GUIDANCE ON HOW TO PREPARE

AN LER.

- IHE LER FORMS.

- A SET OF EXAMPL ES OF POTENTIALLY REPORTABLE EVENTS WITH STAFF COMMENTS ON THE ACTUAL REPORTABILITY OF EACH EVENT.

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4 THE USE OF THE LICENSEE EVENT REPORT

- THE LER IS THE PRINCIPAL MEANS FOR:

- MONITORING THE FREQUENCY OF SAFETY PROBLEMS.

- STUDYING POTENTIAL ACCIDENT PRECURSORS.

- ASSESSING RISK CONTRIBUTIONS.

- IHE LER IS USED BY:

- NRC HEADQUARTERS AND REGIONAL OFFICES INPO

- NSSS VENDORS INDEPENDENT CONSULTANTS AND FIRMS

- NRC CONTRACTORS

- FOREIGN ORGANIZATIONS IHUS, THE LER IS ONE OF THE MOST IMPORTANT, MOST WIDELY READ, AND MOST WIDELY USED DOCUMENTS IN THE INDUSTRY.

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F USES OF OPERATIONAL EXPERIENCE (CONTINUED)

LER ANALYSIS AND EVALUATION PROGRAM hdC SCREENS EACH LER TO:

IDENTIFY THOSE EVENTS OR GENERIC SITUATIONS THAT WARRANT ADDITIONAL ANALYSIS.

IDENTIFY EMERGING TRENDS OR PATTERNS OF POTENTI AL SAFETY SIGNIFICANCE.

A PATTERN OR TREND CAN ORIGINATE FROM:

I

- A SINGLE ENGINEER REVIEWING AN INDIVIDL'AL LER AND RECALLING FROM MEMORY SIMIL AR EVENTS IN OTHER REPORTS, I

- IHE LER IDENTIFYING PREVIOUS OCCURRENCES.

- A PRIORI POSTULAT10N OF A CONCERN.

IHE STATISTICAL TRENDS AND PATTERNS PROGRAM BEING DEVELOPED BY AE00 IS

- DRIVEN BY THE DATA.

1 NOT DEPENDENT ON THE PRIOR FORMUL ATION OF A PARTICULAR C0!1CER!l.

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. . . _ . . . . _ , . . . _ _ , , . _ _ . _ - , _ , _ . . , .._ - -. . _ . . , . - . . . ~ . , - - . - . . , . _ . ~ _

'I OTHER USES OF LER DATA

- STUDY OF COMMON CAUSE FAILURE DATA.

- STUDY OF FAILURE RATE DATA FOR COMPONENTS.

- STUDY OF SYSTEMS INTERACTIONS.

^

STUDY OF HUMAN ENGINEERING AND MAINTENANCE.

- STUDY OF PROBLEMS WITH CURRENT PROCEDURES.

- STUDY OF PRECURSOR IDENTIFICATION AhD ASSESSMENT.

i

- STUDY OF FAULT TREE / EVENT TREE CONSTRUCTION / VALIDATION.

- STUDY OF POTENTIAL GENERIC SAFETY ISSUES.

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NRC FEEDBACK DOCUMENTS THAT USE LER INFORMATION AE00 ENGINEERING EVALUATIONS AND CASE STUDIES IE BULLETINS AND INFORMATION NOTICES

- NRR GENERIC LETTERS, SPECIAL REPORTS, AND SRP REVISIONS POWER REACTOR EVENTS ABNORMAL OCCURRENCE REPORTS TO CONGRESS LER COMPILATION

- NRC CONTRACTOR REPORTS

- NRC STAFF REPORTS PRINTOUTS FROM COMPUTERIZED DATA FILES

- IRENDS AND PATTERNS

SUMMARY

REPORTS.

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4 THE REVISED LER SYSTEM

! FREDERICK J. HEBDON, CHIEF,

! PROGRAM-TECHNOLOGY BRANCH,

' 0FFICE FOR ANALYSIS AND EVALUATION 0F OPERATIONAL DATA >

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L OVERVIEW 0F THE REVISED LER SYSTEM

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IMPROVE LERS FOR OPERATING EXPERIENCE FEEDBACK TO CONFIRM SAFETY MARGINS AND IDENTIFY SAFETY PROBLEMS. .

REVISIONS CRITERIA ARE BASED PRIMARILY ON THE NATURE, COURSE, i , AND CONSEQUENCES OF THE EVENT.

- EVENTS ARE REPORTED REGARDLESS OF THE PLANT OPERATING

,- MODE OR POWER LEVEL.

- REPORTS CONTAIN A DETAILED NARRATIVE DESCRIPTION OF l POTENTIALLY SIGNIFICANT SAFETY EVENTS.

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OVERVIEW 0F~THE REVISED LER SYSTEM (CONTINUED)

- EXPECTED RESUL TS

- FEWER LERS ( ABOUT 50% LESS)

- REPORTS ONLY OF $1GNIFICANT EVENTS

- BETTER REPORTS (MORE USEFUL)

LICENSEES ARE PERMITTED AND ENCOURAGED TO REPORT ANY EVENT THAT DOES NOT MEET THE CRITERIA CONTAINED IN 550 73(A), IF THE EVENT

- MIGHT BE OF SAFETY SIGNIFICANCE,

- MIGHT BE OF GENERIC INTEREST OR CONCERN,

- CONTAINS A LESSON TO BE LEARNED.

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J OPERATIONS PR0HIBITED BY THE TECHNICAL SPECIFICATIONS PARAGRAPH 50 73(A)(2)(1)

"(A) THE COMPLETION OF ANY NUCLEAR PL ANT SHUTDOWN REQUIRED BY THE PLANT'S IECHNICAL SPECIFICATIONS; OR (B) ANY OPERATION PROHIBITED BY THE PL ANT'S TECHNICAL SPECIFICATIONS) OR (C) #

ANY DEVIATION FROM THE PLANT S IECHNICAL SPECIFICATIONS AUTHORIZED PURSUANT TO 550 54(x) 0F THIS PART."

- '"0PERATIONS PROHIBITED" (1.E., VIOLATIONS) DOES NOT INCLUDE ENTERING AN LC0 IF THE CONDITIONS OF THE LC0 ARE MET.

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ENGINEERING JUDGMENT PARAGRAPH 50 73(A)(2)(II)

"ANY EVENT OR CONDITION THAT RESULTED IN THE CONDITION OF THE NUCLEAR POWER PLANT, INCLUDING ITS PRINCIPAL SAFETY BARRIERS, BEING SERIOUSLY DEGRADED, OR THAT RESULTED IN THE NUCLEAR POWER PLANT BEING:

(A) IN AN UNANALYZED CONDITION THAT SIGNIFICANTLY COMPROMISED PLANT SAFETY; (B) IN A CONDITION THAT WAS OUTSIDE THE DESIGN BASIS OF THE PLANT; OR (E) IN'A CONDITION NOT COVERED BY THE PLANT'S OPERATING AND EMERGENCY PROCEDURES."

- LICENSEE MAY USE ENGINEERING JUDGMENT AND EXPERIENCE TO DETERMINE WHETHER AN EVENT IS REPORTABLE UNDER THIS CRITERION.

ENGINEERING JUDGMENT (CONTINUED)

PARAGRAPH 50 73(A)(2)(Ill)

"ANY NATURAL PHENOMENON OR OTHER EXTERNAL CONDITION THAT POSED AN ACTUAL THREAT TO THE SAFETY OF THE NUCLEAR POWER' PLANT OR SIGNIFICANTLY HAMPERED SITE PERSONNEL IN THE PERFORMANCE OF DUTIES NECESSARY FOR THE SAFE OPERATION OF THE NUCLEAR DOWER PLANT."

- LICENSEE IS TO DECIDE IF A PHENOMENON OR CONDITION " POSED

. AN ACTUAL THREAT" TO THE PLANT.

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ENGINEERING JUDGMENT (CONTINUED)

PARAGRAPHS 50 73(A)(2)(v) AND (vi)

"(v) ANY EVENT OR CONDITION THAT ALONE COULD HAVE PREVENTED THE FULFILLMENT OF THE SAFETY FUNCTION OF STRUCTURES OR SYSTEMS THAT ARE NEEDED TO:

(A) SHUT DOWN THE REACTOR AND MAINTAIN IT IN A SAFE SHUTDOWN CONDITION; (B) REMOVE RESIDUAL HEAT; (C) CONTROL THE RELEASE OF RADIOACTIVE MATERIAL; OR (D) MITIGATE THE CONSEQUENCES OF AN ACCIDENT.

(VI) EVENTS COVERED IN PARAGRAPH ( A)(2)(V) 0F THIS SECTION MAY INCLUDE ONE OR MORE PERSONNEL ERRORS, EQUIPMENT FAILURES, AND/OR DISCOVERY OF DESIGN, ANALYSIS, FABRICATION, CONSTRUCTION, AND/OR PROCEDURAL INADEQUAClES. HOWEVER, INDIVIDUAL COMPONENT FAILURES NEED NOT BE REPORTED PURSUANT TO THIS PARAGRAPH IF REDUNDANT E Q U I PM E N T IN THE SAME SYSTEM WAS OPERABLE AND AVAILABLE TO PERFORM THE REQUIRED SAFETY FUNCTION."

- A TECHNICAL JUDGMENT MUST BE MADE WHETHER A FAILURE OR OPERATOR ACTION THAT DID ACTUALLY DISABLE ONE TRAIN OF A SAFETY SYSTEM, COULD HAVE, BUT DID HOT, AFFECT A REDUNDANT TRAIN WITHIN THE ESF SYSTEM.

- REPORTABLE IF THERE IS REASONABLE DOUBT THAT THE FUNCTION-ALLY REDUNDANT TRAIN OR CHANNEL WOULD REMAIN OPERATIONAL UNTIL IT COMPLETED ITS SAFETY FUNCTION OR WAS REPAIRED.

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ENGINEERING JUDGMENT (CONTINUED)

PARAGRAPH 50 73(A)(2)(x)

"ANY EVENT THAT POSED AN ACTUAL THREAT TO THE SAFETY OF THE NUCLEAR POWER PLANT OR SIGNIFICANTLY HAMPERED SITE PERSONNEL IN THE PERFORMANCE OF DUTIES NECESSARY FOR THE SAFE OPERATION OF THE NUCLEAR POWER PLANT INCLUDING FIRES, T0XIC GAS RELEASES, OR RADIOACTIVITY RELEASES."

- LICENSEE IS TO DECIDE IF AN EVENT POSED AN ACTUAL THREAT TO THE PLAN) 9R SIGNIFICANTLY HAMPERED SITE PERSONNEL.

IMPACT ON RELATED REPORTING REQUIREMENTS 10 CFR PART 20 STANDARDS FOR PROTECTION AGAINST RADIATION 520 402 REPORTS OF THEFT OR LOSS OF LICENSED MATERIAL IN 520 402, PARAGRAPH (A) HAS BEEN REVISED; THE INTRODUCTORY TEXT OF PARAGRAPH (B) HAS'BEEN REVISED; AND'A NEW PARAGRAPH (E) HAS BEEN ADDED TO READ AS FOLLOWS:

(A)(1) EACH LICENSEE SHALL REPORT TO THE COMMISSION, BY TELEPHONE, IMMEDIATELY AFTER IT DETERMINES THAT A LOSS OR THEFT OF SUCH CIRCUMSTANCES THAT IT APPEARS TO THE LICENSEE THAT A SUBSTANTIAL HAZARD MAY RESULT TO PERSONS IN UNRESTRICTED AREAS.

(2) REPORTS MUST BE MADE AS FOLLOWS:

(!) LICENSEES HAVING AN INSTALLED EMERGENCY NOTIFICA-TION SYSTEM SHALL MAKE THE REPORTS TO THE NRC OPERATIONS CENTER IN ACCORDANCE WITH 550 72 0F THIS CHAPTER.

(II) ALL OTHER LIC$NSEES SHALL MAKE REPORTS TO THE ADMINISTRATOR OF THE APPROPRI ATE NRC REGIONAL OFFICE LISTED IN APPENDIX D OF THIS PART.

( h .) EACH LICENSEE WHO MAKES A REPORT UNDER PARAGRAPH ( A) 0F THIS SECTION SHALL, WITHIN 30 DAYS AFTER LEARNING OF THE LOSS OR THEFT, MAKE A REPORT IN WRITING TO THE U.S.

NUCLEAR REGULATORY COMMISSION, DOCUMENT CONTROL DESK, WASHINGTON, D.C. 20555, WITH A COPY TO THE APPROPRIATE NRC REGIONAL OFFICE LISTED IN APPENDIX D OF THIS PART.

THE REP 0oT ? HALL INCLUDE THE FOLLOWING INFORMATION:

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IMPACT ON RELATED REPORTING REQUIREMENTS (CONTINUED) 520 402 REPORTS OF THEFT OR LOSS OF LICENSED MATERIAL (CONTINUED)

(E) FOR HOLDERS OF AN OPERATING LICENSE FOR A NUCLEAR POWER PL ANT, THE EVENTS INCLUDED IN PARAGRAPH (B) 0F THIS

, SECTION MUST BE REPORTED IN ACCORDANCE WITH THE PROCEDURES DESCRIBED IN PARAGRAPHS 50 73(B), (C), (D), (E), AND (G) 0F THIS CHAPTER AND MUST INCLUDE THE INFORMATION REQUIRED IN PARAGRAPH (B) 0F THIS SECTION. EVENTS REPORTED'IN ACCORDANCE WITH 550 73 0F THIS CHAPTER NEED NOT BE REPORTED BY A DUPLICATE REPORT UNDER PARAGRAPH (B) 0F THIS SECTION.

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IMPACT ON RELATED REPORTING REQUIREMENTS (CONTINUED)

'10 CFR 20 402 - NO CHANGE IN REPORTING CRITERIA

- IELEPHONE NOTIFICATION VIA THE ENS

- WRITTEN REPORT BY LER 10 CFR 20 403 - NO CHANGE IN REPORTING REQUIREMENTS

- IELEPHONE NOTIFICATION VIA THE ENS 10 CFR'20 405 - NO CHANGE IN REPORTING REQUIREMENTS WRITTEN REPORT BY LER 10 CFR PART 21 - REVISION IN PROGRESS

- REPORTING CRITERIA CONSISTENT WITH 50 72 AND 50 73 10 CFR 50 36 - NO CHANGE IN REPORTING REQUIREMENTS

- TELEPHONE NOTIFICATION VIA THE ENS

- WRITTEN REPORT BY LER 10 CFR 50 55(E) - REVISION IN PROGRESS l

- REPORTING CRITER!A CONSISTENT WITH 50 72 AND 50 73 l

10 CFR 73 71 - REVISION IN PROGRESS

- REPORTING CRITERIA CONSISTENT WITH 50 72 AND 50 73 i

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CONTENT OF THE LER

- 50 73(s) THE LICENSEE EVENT REPORT SHALL CONTAIN:

- 50 73(s)(1) A BRIEF ABSTRACT.

- MAJOR OCCURRENCES.

- ALL COMPONENT FAILURES.

- SIGNIFICANT CORRECTIVE ACTION.

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9 CONTENT OF THE LER (CONTINUED) 50 73(B)(2)(I) A CLEAR, SPECIFIC, NARRATIVE DESCRIPTION OF WHAT OCCURRED SO THAT KNOWLEDGEABLE READERS CONVERSANT WITH THE DESIGN OF COMMERCIAL-NUCLEAR POWER PL ANTS, BUT NOT FAMILLIAR WITH THE DETAILS OF A PARTICUL AR PL ANT, C AN UNDERSTAND THE COMPL ETE EVENT.

- EMPHASIZE HOW SYSTEMS, COMPONENTS, AND OPERATING PERSONNEL PERFORMED.

- DESCRIBE CHARACTERISTICS OF A PL ANT THAT ARE UNIQUE AND THAT INFLUENCED THE EVENT.

- DESCRIBE THE EVENT FROM THE PERSPECTIVE OF THE OPERATOR.

- DO NOT COVER SPECIFIC HARDWARE PROBLEMS IN EXCESSIVE DETAIL.

00 NOT USE TERMS, INITI ALS, OR ACRONYMS THAT ARE ONLY IN LOCAL USE.

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CONTENT OF THE LER (CONTINUED)

- 50 73(B)(2)(il) THE NARRATIVE DESCRIPTION MUST INCLUDE THE FOLLOWING SPECIFIC INFORMATION AS APPROPRIATE FOR THE PARTICULAR EVENT:

(F) THE ENERGY INDUSTRY IDENTIFICATION SYSTEM COMPONENT FUNCTION IDENTIFIER AND SYSTEM NAME OF EACH COMPONENT OR SYSTEM REFERRED TO IN THE LER.

- DEFINED IN IEEE STDS 803-1983, 803A-1983, AND 805-1983

- " SYSTEM NAME" MAY BE EITHER THE FULL NAME ( E.G.,

REACTOR COOLANT SYSTEM) OR THE TWO LETTER SYSTEM CODE ( E .G . , AB).

WHEN THE NAME IS LONG THE CODE SHOULD BE USED.

- INCLUDE THE NAME AND/OR CODES IN PARENTHESIS FOLLOWING THE FIRST REFERENCE TO A SYSTEM OR COMPONENT IN THE TEXT OF THE LER.

- IHE NAME AND/0R CODE NEED NOT BE REPEATED WITH EACH SUBSEQUENCE REFERENCE TO THE SAME COMPONENT OR SYSTEM.

- DO NOT INCLUDE THE PARENTHETICAL NAMES OR CODES IN THE ABSTRACT SECTION.

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! - INTERPRETATION OF A SYSTEM BOUNDARY SHOULD BE i CONSISTENT WITH THE COMPARABLE SYSTEM DESCRIPTIONS AND INTERPRETATIONS CONTAINED IN THE NPRDS l REPORTABLE SYSTEM AND COMPONENT MANUAL.

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CONTENT OF THE LER (CONTINUED) 50 73(B)(3) AN ASSESSMENT OF THE SAFETY CONSEQUENCES AND IMPLICATIONS OF THE EVENT.

INCLUDE THE AVAILABILITY OF OTHER SYSTEMS OR COMPONENTS THAT COULD HAVE PERFORM 2D THE SAME FUNCTION.

- BASED ON THE CONDITIONS EXISTING AT THE TIME OF THE EVENT.

- ASSESSMENT OF THE EVENT UNDER ALTERNATIVE CONDITIONS MUST BE INCLUDED IF THE INCIDENT WOULD HAVE BEEN MORE

. SEVERE UNDER REASONABLE AND CREDIBLE ALTERNATIVE CONDITIONS.

- 50 73(B)(4) A DESCRIPTION OF ANY CORRECTIVE ACTIONS.

- DESCRIBE CORRECTIVE ACTIONS ON SIMILAR OR RELATED COMPONENTS THAT WERE DONE AS A DIRECT RESULT OF THE EVENT.

- DISCUSS WHY PRIOR CORRECTIVE ACTION DID NOT PREVENT RECURRENCE.

- ONLY SUBSTANTIAL CHANGES IN THE CORRECTIVE ACTION NEED BE REPORTED AS A SUPPLEMENTAL LER.

- 50 73(B)(5) REFERENCE TO ANY PREVIOUS SIMILAR EVENTS.

- 50 73(B)(6) THE NAME AND TELEPHONE NUMBER OF A CONTACT.

9

INSTRUCTIONS FOR COMPLETING THE LER FORMS-GENERAL INSTRUCTIONS

- ERRORS DISCOVERED IN AN LER SHOULD BE CORRECTED IN A REVISED REPORT.

- IHE REVISED REPORT SHOULD BE A COMPLETE ENTITY AND NOT CONTAIN ONLY SUPPLEMENTARY OR REVISED INFORMATION.

- A REVISION SHOULD NOT BE USED TO REPORT SUBSEQUENT FAILURES OF THE SAME OR LIKE COMPONENTS.

- ONLY SUBSTANTIAL INFORMATION THAT WOULD SIGNIFICANTLY CHANGE A READER'S PERCEPTION OF THE COURSE OR CONSEQUENCES OF AN EVENT, OR SUBSTANTIAL CHANGES IN THE CORRECTIVE ACTION PL ANNED BY THE LICENSEE NEED BE REPORTED IN A REVISED LER.

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INSTRUCTIONS FOR COMPLETING THE LER FORM (CONTINUEDi ITEM 6: REPORT NUMBER EVENT YEAR.

- BASED ON EVENT DATE, NOT REPORT DATE.

SEQUENTIAL REPORT NUMBER.

- EACH NUCLEAR UNIT SHOULD HAVE ITS OWN SET OF SEQUENTIAL REPORTS NUMBERS.

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BEGIN WITH 001 FOR THE FIRST EVENT THAT OCCURRED IN EACH CALENDAR YEAR.

- FOR EVENTS COMMON TO MORE THAN ONE UNIT OF A MULTIPLE UNIT SITE, ASSIGN THE SEQUENTIAL NUMBER FOR THE LOWEST NUMBERED NUCLEAR UNIT.

IF THE SQUENTIAL N UM B E R IS ASSIGNED TO AN EVENT, AND IT IS SUBSEQUENTLY DETERMINED THAT THE EVENT IS NOT REPORTABLE, WRITE A BRIEF LETTER TO THE NRC NOTING THAT "LER NUMBER XXX FOR DOCKET 05000YYY WILL NOT BE USED."

- REVISION NUMBER.

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INSTRUCTIONS FOR COMPLETING THE LER FORM' (CONTINUED)

ITEM ll: REPORTING REQUIREMENTS

- CHECK ONE OR MORE BLOCKS DEPENDING ON THE REPORTING REQUIRE-MENTS THAT WERE MET BY THE EVENT.

- A SINGLE EVENT CAN MEET MORE THAN ONE REPORTING CRITERIA.

FOR EXAMPL E:

- IF AS A RESULT OF SABOTAGE (REPORTABLE UNDER 573 71(B)} A SAFETY SYSTEM FAILED TO FUNCTION

( REPORTABLE UNDER 550 73( A)(2)(v) } AND THE NET RESULT WAS A RELEASE OF RADI0 ACTIVE MATERIAL IN A RESTRICTED AREA THAT EXCEEDED THE A PPL IC ABLE L ICENSE LIMIT (REPORTABLE UNDER 520 405(A)(1)(!!!)}.

- CHECK 573 71(B), 50 73(A)(2)(v), AND 520 405 (A)(1)(Ill).

- AN EVENT CAN BE REPORTED AS AN LER EVEN IF IT DOES NOT MEET ANY OF THE SPECIFIC CRITERIA IN 50 73 "0THER" BLOCK SHOULD BE USED IF A REPORTING REQUIREMENT IS MET THAT IS NOT SPECIFIED IN ITEM 11 FOR EXAMPLE, AN OPTIONAL REPORT OF AN UNUSUAL EVENT.

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INSTRUCTIONS FOR COMPLETING THE LER FORM (CONTINUED)

ITEM 13: COMPONENT FAILURES FAILURE IS DEFINED AS THE TERMINATION OF THE ABILITY OF AN ITEM TO PERFORM ITS REQUIRED FUNCTION.

- INCLUDES COMPLETE AND DEGRADED FAILURES.

FOR MULTIPLE FAILURES ONLY A SINGLE ENTRY IS REQUIRED IN ITEM 13

- CAUSE: THE ROOT CAUSE OF.THE FAILURE FROM APPENDIX 8 0F NUREG-1022

- SYSTEM: FROM IEEE STANDARD 805-1983 COMPONENT: FROM IEEE STANDARD 803A-1983

- COMPONENT MANUFACTURER:

- FROM THE NPRDS REPORTING PROCEDURES MANUAL.

- MANUFACTURERS THAT ARE NOT INCLUDED IN THE LIST SHOULD BE DESIGNATED X999 j

REPORTABLE TO NPRDS: "Y" OR "N".

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- ADDITIONAL COMPONENT FAILURES MAY BE CODED ON ONE OR MORE FAILURE CONTINUATION SHEETS (NRC-366B).

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ITEM 17: IEXT NO PRESCRIBED FORMAT FOR THE LER TEXT.

- WRITTEN IN THE FORMAT THAT MOST CLEARLY DESCRIBES THE EVENT.

- 50 73(B) IS NOT INTENDED AS AN OUTLINE OF THE TEXT FORMAT.

- 50 73(B) .SHOULD BE REVIEWED TO INSURE THAT APPL IC ABLE SUBJECT HAVE BEEN ADEQUATELY ADDRESSED IN THE TEXT.

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- 50 73(D) - AN LER MUST BE SUBMITTED WITHIN 30 DAYS OF DISCO.VERY. y ~~~~~

- THE LER SHOULD BE SENT TO THE U.S. NUCLEAR REGUL ATORY COMMI SSION, DOCUMENT CONTROL DESK, WA S H I N G T O N , D.C. 20555; WITH A COPY TO THE APPROPRIATE NRC REGIONAL OFFICE. _.

- 50 73(E) IHE LER MUST BE OF SUFFICIENT QUALITY TO PERMIT LEGIBLE REPRODUCTION AND MICR0 GRAPHIC PROCESSING.

. - 50 73(F) UPON WRITTEN REQUEST FROM A LICENSEE INCLUDING ADEQUATE JUSTIFICATION OR AT THE INITIATION OF THE NRC STAFF, THE NRC EXECUTIVE DIRECTOR FOR OPERATIONS MAY, BY A' LETTER TO THE LICENSEE, GRANT EXEMPTIONS.

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- 50 73(G) 50 73 REPL ACE (S) ALL EXISTING REQUIREMENTS FOR LICENSEES TO REPORT " REPORTABLE OCCURRENCES" AS DEFINED IN INDIVIDUAL PL ANT IECHNIC AL SPECIFICATIONS.

- USUALLY TITLED " PROMPT NOTIFICATION WITH WRITTEN

, . FOLLOWUP" (SECTION 6 9 1 8) AND "IHIRTY DAY WR ITTEN 4' REPORTS" (SECTION 6 9 1 9).

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