ML20209C199
| ML20209C199 | |
| Person / Time | |
|---|---|
| Issue date: | 12/16/1982 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20209C203 | List: |
| References | |
| FOIA-86-729, RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8306290039 | |
| Download: ML20209C199 (5) | |
Text
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- ? UNITED STATES
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NUCLEAR REGULATORY COMMISSION 8- o REGION ll -l
+5 101 MARIETTA ST N.W., SufTE 3100
'C ATLANTA, GEORGIA 30303
- DEC.16 1982
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MEMORANDUM FOR: Richard C. DeYoung, Director Office of Inspection and Enforcement FROM: James P. O'Reilly, Regional Administrator
SUBJECT:
DRAFT FINAL RULE CHANGE TO 10 CFR 50.72 Your December 3,1982, memorandum requested comments on the subject proposed rule change.
Because of the short turnaround time and the fact that we did not receive the complete text of the proposed new 50.72, we were not able to perform as compre-hensive a review as we would have preferred. Notwithstanding, our review, i combined with our extensive experiences, raised a number of questions which we believe should be addressed. Recognizing that another opportunity to solve the
, important emergency reporting dilemma may not be forthcoming in the near future, we urge careful consideration of our comments at this time.
We continue to have serious concern with regard to the impact on the public, the NRC and on licensee resources created by the excessive submittals of immediate non-emergency reports through the emergency center and emergency network. In effect, the NRC has defined such reports as emergencies. As the proposed new
. rule is written, we do not believe that a proper reduction in such " emergency" i reporting will be realized, in spite of the intent of the draft rule. We wish to emphasize that we are not commenting on what reports the NRC needs, only when and how the NRC receives them.
l Although there has been minor relaxation of notification requirements in the proposal, particularly in the reporting time frames, retention of the NUREG 0654 criteria for Unusual Events does little to alleviate the serious problems associ-at'd e with inappropriate emergency reporting thresholds. Even worse, the proposed rule incorporates directly the criteria of NUREG 0654 into 50.72. That is, in -
our view, conceptually wrong.
NUREG 0654 should be revised to eliminate the emergency category " Unusual Event".
Instead, for this category, NUREG 0654 should reference 50.'72 events as requiring one hour notification to the NRC for evaluation.
Another concern is the complexity introduced by having the two reporting time frames, one (1) hour and four (4) hours in this rule, which was intended to cover only immediately reportable events. Our evaluation of these time frames reveals that for some of the events a report to the Regional Office during work hours would suffice. We recommend this as the second more permissive time frame. Also, we find that in several cases, a written report would be adequate CONTACT: F. J. Long iage
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LRichard C. DeYoung 2 DEC 161962 -
without ' prior notification, where only statistical or historical information is involved. We prefer maintaining the one hour time for reports which are neces-sary on an urgent basis. The general yardstick we should apply is whether or not we will immediately react to that notification.
Your memorandum also requested our reaction to two specific items. With regard to item (6) on page 12, we have no particular problem with it; although- the wording could be improved. A threat to plant safety is understandable but we do 3 not follow the threat to personnel safety. We believe the second part should i therefore be worded to describe an event or act that prevents, or interferes with, personnel performing safety functions.
i With regard to item (6) on page 21, we believe this criterion is vague and could-be interpreted to be a catchall. As written, this criterion could restore the reductions in notifications' brought about by improvements that were incorporated in other criteria.
Additional specific comments are contained in the enclosure.
% {. 9 ames P. O'Reilly
Enclosure:
Additional Comments on Draft Rule '
Change 10 CFR 50.72 j-l l
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.l ENCLOSURE ADDITIONAL COMMENTS ON DRAFT RULE CHANGE TO 10 CFR 50.72
- 1. Page 1 - clarity: We = do not believe that by simply incorporating the -
NUREG -0654 criteria in 50.72 enhances public safety or improves the clarity pp or the legal basis of the requirements. A thorough review of 0654 criteria r is neceaary. The NRC rule-(50.72) should be the basic requirement which would be factored into the NUREG document to satisfy emergency needs.
- 2. Page 2 - Report Timing: We believe 50.72 should be limited to emergency notification requirements, which would require reporting to NRC within the {p p hour. Any acceptable time frame greater than one hour would not constitute -
an emergency situation, and therefore need not be in 50.72.
- 3. Page 4 - Table: We find the table to be somewhat confusing. QN
- 4. Page 5 - Criterion (1): The scope has changed significantly by omission of "immediate." This would include essentially all LCO conditions without i ()
regard to action statements of lengthy duration which may precede initiating shutdown. We also note the use of the word " prompt" which by usage is x within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while the word "immediate" means within one hour, p
- 5. Page 6 - 50.72(b)(2)(iv): The paragraph should be changed to a specific coolant dose equivalent I-131 value rather than stating that a report is required if T.S. are exceeded. At least one plant in. Region II (e.g. Turkey .
Point) has no T.S. limit on iodine spikes. PWRs with fuel element defects can experience I-131 spikes greater than the T.S. limits following SCRAMS.
This immediate notification threshold should be set such that, if exceeded, it is indicative of a situation which warrants immediate action.
- 6. Page 6 - Criterion (2): Item (1) - how about conditions that are governed?
Recommend delete this item. Item (iii) - Is this value reasonable? It seems too small got accumulative or single measurement.
l 7. Page 7 - Criterion (2)(iv): Recommend this be d le ed. It appears to be-j covered by the activity release criterion. pp g,,A t t /M r W A WA f
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- 8. Page 7 - Criterion (3): Clarify to reflect events that interfere with site personnel performing duties...
- 9. Page 10 - Criterion (4): We do not believe this need be a one hour report. N
! Recommend deletion from 50.72(b) and consider placing in 50.73.
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- 10. Page 11 - Criterion (5): We believe that criterion must define what a major loss is. The Safety Parameter Display System is not a required system, why must its loss be immediately reportable?
- 11. Page 12 - Criterion (b): The example events are too general and need to be more specifically described. We do not believe, e.g., that all " fires" need be immediately reportable; likewise " strikes" should be described as those consisting of unanticipated walkouts.
- 12. Page 14 - Criterion (1): We believe this type report could be delayed to the next work day and reported to the regional offices. The criterion is also too general in that many things may be found that fit, but have no urgency. Would the reportability be the same if the plant were in extended shutdown? Suppose the head is off the vessel etc.?
- 13. Page 15 - Criterion (2): We believe it is necessary to report failure of ESF to actuate, not the actuation.
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- 14. Page 16 - Criterion (3): Clarify to specify events found while operating, (or) when the function was required. We also believe the lead-in should include components as well as structures or systems.
We interpret this criterion to mean the loss of an entire system, not the loss of one train of a redundant system. This should be clearly defined.
- 15. Page 18 - Criterion (4): We believe this should be a one hour report.
50.72(c)(4)(1): The reporting level for unplanned releases still appears to be too low. The way it's written we're requiring immediate notification for unplanned releases that could result in offsite doses (not likely to be received by any specific individual) of as high as 0.14 mrem whole body equivalent. This threshold should be raised to at least approximately 0.5 mrem (7X Technical Specification averaged over 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />).
50.72(c)(4)(1-iii): The criterion establishes reporting requirements for release of noble gases in air and radioactivity, in general, in liquids.
However, the paragraph does not include a reporting requirement for exceed-ing the Technical Specification limit for particulate and iodine release. A section (iv) should be added which requires a report for release which exceeds the Technical Specification limit particulate radioactivity (with greater than an eight day half-life) and iodine releases.
(4)(111) The paragraph does not define " receiving water." This could be interpreted as the unrestricted area of a river or lake, or the discharge canal where most plants release itquid radioactive waste. The discharge canal is considered within the restricted area by most utilities. This should read " liquid releases that exceed two times the limiting combined MPC. . .to an unrestricted area. . .
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- 16. Page 20 - Criterion (5): The basis is clear but the gule'is not. Use the first line of the basis, i.e., "an onsite fatality or transport of a contaminated...."-
- 17. Page 21 - Criterion (6): Recommend delete. These need only be reported to regional offices during regular work hours.
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