ML20213F105

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Clarifies Requirement for Licensees to Rept Event or Condition That Results in Multiple Failures of Reactor Protection Sys to Headquarters Operations Ctr.Guidance to Rules Provided in NUREG-1022,10CFR50.72 & 50.73
ML20213F105
Person / Time
Site: Susquehanna, 05000000
Issue date: 01/10/1985
From: Deyoung R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: James Keppler, Martin J, Martin R, Murley T, James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20213E720 List:
References
FOIA-86-729, RTR-NUREG-1022 NUDOCS 8501140504
Download: ML20213F105 (3)
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Text

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JAN'101985 MEMORANDUM FOR: Thomas E. Murley, Regional Administrator, Region I James P. O'Reilly, Regional Administrator, Region II -

James G. Keppler, Regional Administrator, Region III Robert D. Martin, Regional Administrator, Region IV John B. Martin, Regional Administrator, Region V FROM: Richard C. DeYoung, Director Office of Inspection and Enforcement

SUBJECT:

NOTIFICATIONS TO THE NRC OPERATIONS CENTER AND REPORTING EVENTS IN LICENSEE EVENT REPORTS The. purpose of this memorandum is to clarify the requirement for licensees to report to the Headquarters Operations Center an event or conditica that results in multiple failures of the reactor protection system (RPS). This guidance is also applicable to the requirement for licensees to report events as Licensee Event Reports (LERs). This issue has arisen as a result of a recent event at

.Susquehanna Unit I where multiple failures occurred in the scram system, but the licensee did not consider it necessary to report the fa*1ures to the Headquarters Operations Center.

The Susquehanna Unit 1 event occurred on October 6,1984, while performing single control rod scram time testing. One of the control rods scheduled for testing failed to scram when the scram pilot solenoid valve stuck in the energized position. Subsequent testing of th'e remaining rods revealed that 3 additional rods would not scram and that 11 control rods exhibited initial hesitation. Both Units 1 and 2 were at power when the problems occurred.

The paragraph of 10 CFR 50.72 that requires reporting of all multiple failures and some single failures is paragraph 50.72(b)(2)(iii), which requires the licensee to notify the NRC Operations Center as soon as practical and in all cases within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the occurrence of:

CONTACTS:

10 CFR 50.72 C. E. Rossi, IE (301)492-4193 E. W. Weiss, IE (301)492-9005 10 CFR 50.73 F. J. Hebdon, AE0D (301)492-4480 c Wlb m '

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( 1 Regional Administrators l l

4 (iii) Any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that  :

are needed to:

2 (a) Sh'ut 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.

The comparable paragraph in 50.73, which contains identical words, is .

50.73(a)(2)(v).

Several written documents provide guidance on interpreting these rules including NUREG-1022 " Licensee Event Report System," Supplement I to that NUREG, and the ,

preambles to the Federal Register Notices used to publish 10 CFR 50.72 and 50.73. For example, in regard to what is meant by "could" the Federal Register 4 Notices that published these rules (10 CFR 50.72 and 10 CFR 50.73) have a preamble that says: -

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Finally, the Commission recognizes that the licensee has to decide when personnel actions could have prevented fulfillment of a safety function. For example, when an individual improperly operates or maintains a component, that person might conceivably have made the same error for all of the functionally redundant components (e.g.,

if an individual incorrectly calibrates one bistable amplifier in the Reactor Protection System, that person could conceivably incorrectly calibrate all bistable amplifiers).

In regard to whether even a single component failure is reportable, the preamble to the Federal Register Notice says: ,

If a component fails by an apparently random mechanism, it may or

may not be reportable if the functionally redundant component could fail by the same mechanism.

Anytime a single rod fails to scram, the licensee may have a reasonable doubt that other rods would fail to scram. If multiple rods fail to scram, there is little doubt that other rods could be affected and, thus, this is an event or condition that could prevent the fulfillment of the safety function (i.e., the RPS scram) needed to shut down the reactor.

In your interactions with licensees, please stress that the intent of both 50.72 and 50.73 is that multiple failures in safety systems should be reported. If your staff or. licensees have questions regarding interpretation of 10 CFR 50.72, j please contact Eric Weiss or Ernie Rossi in IE. If your staff or licensees have h

Regional Administrators .

guestions regarding interpretation of 10 CFR 50.73, please contact Fred Hebdon f.FTS492-4480) in AEOD. We will be glad to participate in discussions on problems which you have with interpretation aad/or enforcement of these rules.

OriginalSigned By b M. Taylor Richard C. DeYoung, Director Office of Inspection and Enforcement cc w/ enclosure:

J. Axelrad, IE H. Denton, NRR G. Holahan, NRR

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