ML20207S876
| ML20207S876 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/05/1987 |
| From: | Morgan H SOUTHERN CALIFORNIA EDISON CO. |
| To: | Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 8703200358 | |
| Download: ML20207S876 (6) | |
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Southem Califomia Edison Company 4V,,,
SAN ONOFRE NUCLEAR GENERATING STATION
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If P. O. BOX 128
/f SAN CLEMENTE. CAUFORNIA 92672 H.E. MORGAN TELEPHONE-eranon wa=4 ara March 5, 1987 U. S. Nuclear Regulatory Comission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596-5368 Attention:
Mr. P. Johnson,Section III Chief Reactor Projects Branch
Dear Sir:
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Subject:
Docket Nos. 50-206, 50-361 and 50-362 Reporting of Engineered Safety Feature Actuations San Onofre Nuclear Generating Station, Units 1, 2, and 3 1
During a recent Region V inspection, which included a review of procedures implementing the notification and reporting requirements of 10CFR50.72 and 10CFR50.73, respectively, the implementation of one such requirement was discussed.
In particular, it was indicated that SCE procedure S0123-0-14, entitled " Notification and Reporting of Significant Events", which defines what Engineered Safety Feature (ESF) actuations need not be verbally reported to the EC Operations Center within four hours was questioned.
In a subsequent telephone conversation, SCE indicated that the bases for our understanding of the reporting requirements in this regard, would be provided to the Region.
The enclosure' to this letter is intended to fulfill that commitment. If 4
there are any questions or if additional infomation is required, please contact me.
87032 g g 7500 206 M{M gDR PDR Enclosure cc: Mr. F. R. Huey, USNRC Senior Resident Inspector, SONGS I\\
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NOTIFICATION AND REPORTING TO THE NRC 0F ENGINEERED SAFETY FEATURE ACTUATIONS PURSUANT TO 10CFR50.72 and 10CFR50.73 10C5R50.72(b)(2)(if) and.10CFR 50.73(a)(2)(iv) require that the NRC be
- notified within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and that a 30 day Licensee Event Report (LER) be
- provided for
"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 a part of the preglanned sequence during testing or reactor operation need not be reported.
SCE procedure 50123-0-14, entitled " Notification and Reporting of Significant Events" provides. instructions to operators intended to differentiate those events that are not notifiable from those that are. These instructions are consistent with the above rules in that they identify those preplanned activities, the perfomance of which results in actuations.
Ou' interpretation of the' requirements has evolved, along with the rules r
themselves. The evolution of the rules and discussion pertaining to our understanding of their meaning is provided below.
l NOTIFICATION AND REPORTING RULES:
4 On February 29, 1980 the NRC published in the Federal Register an immediately effective Rule (10CFR50.72) entitled "Immediate Reporting of Significant i
Events at Operating Nuclear Power Reactors". The basis and intent of-the Rule was stated under the heading of " Supplementary Infomation" from which the following statements are excerpted: (with EMPHASIS added)
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o "The capability of the RC to make timely decisions and to provide adequate assurances regarding actual or potential threats to public health or safety, depends heavily on the rapidity with which SIGNIFICANT EVENTS are communicated by nuclear power reactor licensees to NRC."
o "RC has an important obligation to collect facts quickly and accurately about SIGNIFICANT EVENTS, assess the facts, take necessary action, and infom the public about the extent of the threat, if any, to public heal th and safety."
o "Af ter the accident at Three Mile Island on March 28, 1979, the NRC staff
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acted to ensure the timely and accurate flow of infomation from licensees of operating nuclear power reactors following SIGNIFICANT E VENTS. "
o "When (red phones) are picked up to report SIGNIFICANT EVENTS, they automatically ring at the NRC Operations Center and can be held open as long as needed."
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'"The events which are described in ' etail in the rule, include SERIOUS
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d EVENTS that could result in an~ impact on the public health and safety such as those leading to initiation of the licensee's emergency plan or.
any section of the_ plan, the causing of the nuclear power plant to be in
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'an uncontrolled condition, the exceeding of a safety limit, an act of sabotage, or an uncontrolled release of radioactivity."
These and other statements in this Fe!eral Register Notice, indicate that the NRC prompt notification requirements were established to appropriately inform the RC of SIGNIFICANT EVENTS that had the' potential of having some threat to the health and. safety of the public.
Although the Rule was published and became effective on February 29,1980 with no prior opportunity for licensee or public comment, comments were subsequently provided by a number of licensees.
In a Federal Register notice dated
' Decenber 21, 1981, proposing a revision to that rule, the NRC states that "A
.significant neber of comments stated that the February 29,1980 final regulation..; contained many requirements -(citing the ESF actuation reporting rule, amongst others) that were vague, too broad in scope, and ambiguous." In addition, the RC goes on to say that, "The staff's experience has indicated an agreement with many of the concerns of the commenters regarding unnecessary.
notifications to the EC.
All of the new provisions in the proposed rule reflect these concerns by being more specife 'as to what SIGNIFICANT EVENTS should be reported to the NRC.
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In regard to the ESF actuation notification requirement the following parenthetical expression was proposed to be added:
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" Actuation of ESF, including the RPS, which results from and is a part of the i
planned sequence during surveillance testing or nomal reactor shutdown, need not be reported."
4 Although this " clarification" may have somewhat reduced the neber of i
unnecessary notifications, it did not address ~a number of other aspects of the requirement that appeared inconsistent with the original purpose and intent of the rule;= (i.e. spurious or inadvertent actuations of those ESF that are i
promptly determined to not be indicative of any health or safety threat to l
either plant personnel or the public and are not otherwise a significant event).
l On May 6,1982, in a proposed rule published in the Federal Register l
addressing the Licensee Event Report (LER) System, correlation between the notification rule (10CFR50.72) and the LER rule (10CFR50.73) was made, and again, the matter of SIGIIFICANCE was discussed. Consistent with comments that
.... encouraged the NRC to reduce the overall level of reporting by limiting i
the scope to only those occurrences that are of major safety SIGNIFICANCE",
the NRC states: "In trying to develop criteria for the identification of l
events reportable as LERs, the Comission has concentrated on the consequences of the event as the measure of SIGNIFICANCE." Here again, the indication is that inconsequential ESF actuations need not be reported.
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It must be noted that, in regard to " notification" and " reporting" of ESF' ~
actuations, both the 10CFR50.72 and 50.73 rules are worded essentially identically. The guidance or clarifying statements relating to "ESF actuations", in general, is therefore considered to apply to both -
" notification" and " reporting" requirements.
In the " Paragraph-by-Paragraph Explanation of the LER Rule", (Ref. FR Notice dated May'6,1982), -the RC explicitly states that "Actuations that need not be reported are those initiated for reasons other than to mitigate the consequences of an event (e.g., at the discretion of the plant operators, as part of a planned procedure)".
This exemption from notification and/or reporting of certain ESF actuations is understood by SCE to mean that those having little or no SIGNIFICANCE or those of no " consequence" to continued plant operation, or the health and safety of plant personnel or the public, are not to be reported.
Sinilar guidance is provided in the publication of the final notification rule (Federal Register notice dated August 29, 1983), as well as in the final LER rule (Federal Register notice dated July 26, 1983).
CONCLUSIONS:
SCE, therefore, considers that notifying the NRC Operations Center on the Red Phone and fomally reporting the inconsequential or insignificant actuations of ESFs, in particular those initiated by very sensitive radiation monitors, and for which a response to planned or known operational events is expected, j
is inconsistent with the original purpose of these reporting requirements and inconsistent with the requirements of the rule itself.
3 We believe that spurious and/or inadvertent actuation of major Engineered i
Safety Features (e.g. the Reactor Protection System (RPS), Safety Injection j
System (SIAS), Containment Spray System (CSS), Containment Isolation System j
(CI AS), Main Steam Isolation System (MSIS), etc. ), for any reason, are actuations which would most certainly be considered SIGNIFICANT and have 4
i negative consequences in regard to continued nomal power operations.
It is j
appropriate, therefore, that NRC be promptly informed.
However, actuation of the Control Room Isolation System (CRIS), Toxic Gas l
Isolation System (TGIS), Fuel Handling Isolation System (FHIS), and 1
Containment Purge Isolation Systen (CPIS), each actuated by conservatively set i
radiation monitors, which are also very sensitive to electromagnetic interference and sihject to frequent, periodic maintenance and surveillance activity that increases the probability of inadvertent actuation, should only require notification by Red Phone and/or reporting in an LER, when these monitors are actuated by valid enviornmental conditions. Since there is l
little or no consequence to the inadvertent or spurious actuation of any of i
these, and invalid actuations are of no safety SIGNIFICANCE, these should not be so reported.
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' It must be noted here that not all nuclear power facilities contain CRIS, TGIS,. FHIS, or CPIS, and some that do, may or may not consider these as -
" Engineered Safety Features", the actuation of which is notifiable or reportable pursuant to the above rules. Section 7;3 of NUREG-0800 (Standard
- Review Plan) does not include these in a listing of " Typical ESF systems" nor is the term " Engineered Safety Features" found in regulatory guidance dociments prior to 1975 when the tenn appears to first be used in Standard Technical Specifications and Chapter 6 of NUREG 0800.
More than half the operating units in' the country, (licensed prior to 1975) therefore, may or may l
not report actuation of these as such.
i Notwithstanding the above, SCE has considered other guidance published in the above Federal Register Notices, as well as in NUREG-1022 " Licensee Event l_
Reporting System and its supplements, wherein the NRC indicates they are interested in unnecessary, spurious and/or inadvertent actuations of any.ESF t
except those "that resulted from and were part of the preplanned secuence during testing or reactor operation..."
Disregarding the SIGNIFICANCE issue discussed in the publication of the rules noted above, and based on this " preplanned sequence" guidance, SCE procedures require that the NRC be notified of all ESF actuations within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and that an LER be written for each,-EXCEPT when the actuation is attributed to the
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performance of " preplanned" activities which, either require such actuations be initiated or which, based on previous experience, are expected to result in such actuations. Excluding these, SCE notified the NRC of 34 spurious and/or j
inadvertent actuations of ESFs we considered to be INSIGNIFICANT and inconse-quential, in 1986 alone, and have reported 7 such actuations thus far in 1987.
l We believe procedure S0123-0-14 provides appropriate guidance to operators and plant staff to consider when, or if, the actuation of an ESF is "part of a preplanned sequence....", and whether or not the NRC needs, therefore, to be l
notified within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
i Whene,'er any ESF actuation occurs, operators are required to respond by first i
verifying that the ESF is functioning as it was designed to function and then attempt to determine if the actuation was valid (i.e., the sensed parameter j
had indeed reached its actuation setpoint).
If this cannot be confirmed by independent verification (e.
printouts, or manual survey)g., review of strip chart recorders, computer 4
, and there is nothing confirming the need for the l
i ESF to be functioning, the ESF is then restored to standby status, and the cause of the actuation investigated.
Except in those instances where the actuation is determined to be part of a preplanned sequence of testing, main-tenance or any operation known to result in such actuation, the NRC is notified within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
If no reason for the actuation can be determined within that 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period, the NRC is notified that the actuation was " spurious".
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.... We believe, however, that the original purpose of both the notification rule (10CFR50.72), as well as the reporting rule (10CFR50.73), was not to further distract licensed operators from their licensed duties, nor further increase the administrative burden on Licensee management and staff to produce formal, written reports of such INSIGNIFICANT and inconsequential actuations.
If the NRC is interested in receiving reports on these, SCE believes they should be reported in periodic sumaries provided to Nuclear Plant Reliability Data System, rather than requiring that operators notify NRC Operations Center within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and that a LER be written.
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