ML20214R782

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Forwards Draft Final Changes to 10CFR50.72.Comments Requested by 821210 So That Revised Version Reflecting Comments Can Be Ready by 821217
ML20214R782
Person / Time
Issue date: 12/03/1982
From: Deyoung R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Haynes R, James Keppler, 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)
Shared Package
ML20213E720 List:
References
FOIA-86-729 NUDOCS 8612080090
Download: ML20214R782 (11)


Text

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. 5 q ..... ya DEC 0 31982 MEMORANDUM FOR: R. C. Haynes, Region I J. P. O'Reilly, Region II J. G. Keppler, Region III J. T. Collins, Region IV R. H. Engelken, Region V FROM: Richard C. DeYoung, Director Office of Inspection and Enforcement

SUBJECT:

DRAFT FINAL RULE CHANGE TO 10 CFR 50.72 The subject draft rule change, which takes into account comments received on.

the proposed rule as published in the Federal Register, is being provided for your comments.

During today's briefing of the Regional Administrators, the Director of Inspection and Enforcement will discuss the ongoing efforts related to rule changes for 10 CFR 50.72, 10 CFR 50.5.5(e) and 10 CFR 21. The 10 CFR 50.72 is on a tight schedule that the Commission has set for 10 CFR 73.

Because of the close relationship between 10 CFR 50.72 and 10 CFR 50.73, they both must go forward at the same time. In order to achieve this we must expedite the comment process for 10 CFR 50.72. Therefore, we need your .

coments on 10 CFR 50.72 by December 10, 1982 so that a revised version reflecting your comments can be ready for office level concurrence by December 17, 1982. For your convenience a copy of the current draft 10 CFR 50.73 is also being provided today for your use.

We are soliciting your comments in general to the proposed 10 CFR 50.72 and would like your reaction to two specific items. Namely; (1) page 12, item

"(6)" the wording of this item should be changed to clearly indicate that only those events affectirg the safety of the plant need to be repo"ted, and (2) page 21, item "l6)", it should be recognized that state notification, at least initially, may indirectly tie us to the old reporting requi~ements. r 40.

Although, this letter and attached ,opyf of 10 CFR 73 4 are being provided via Rapifax, the comment copy of 10 CFR"72 itself is being sent today via the "5520" word processing system. 4 Please provide your comments to Eric Weiss (492-4973) of my staff.

8612080090 861201 p h Kd N 29 PDR picha C.Dekoung, Director s' Offic of Inspection and Enforcement cc: J. H. Sniezek, IE E. L. Jordan, IE J. Heltemes, AE0D W. R. Mills, IE F. Hebdon, AE0D E. W. Weiss, IE ,

Procosed 50.73 Draft Final 50.73 e-

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(1}' Ary event resulting in manual or (4) Any event that resulted in, actuation c~n automatic actuation or the need for of, Engineered Safety Feature (ESF),

actuation of any Engineered Safety including the Reactor Portection System Fenture (ESF), including the Reactor (RPS). Actuation of an ESF, including

-Protection System (RPS). Actuation of the RPS, that resulted from and is part an ESF, including the RPS, that of the preplanned sequence during sur-results from and is part of the pre- veillance testing or nomal reac(op planned sequence during surveillance operation need not be reported. In

,u m testing or normal reactor shutdown addition, reactor trips whi+ occurred LsWLE.D ti.e. PLc4w1 IS 901 SWuqoaqc go.it;4.

need not be reported. -k the car: 2 i- h.e wi g r k d ( c . g . , d'_'r M on.so u<nn oo, start up) ::y be reported in : singic repert, uwass .1w-1 su, ova. on. nona oc we., o1 wt. ca.ne.rt.m comoie eJ 1Ws' sewob.

Basis for Changes:

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PgaAstapu In response to the pubic comments, the staff has revised this s+4-terton ,

to require the reporting of only those reactor trips that occur while the recctor is above 507, power. In re'rospect, t the staff agrees that reactor trips that o'ccur from below 507, power and that do not meet any of the attaca.a ms other c-iter:: contained in this section, are not su'fficiently signifi-

, cant to warrant reporting as LERs. Therefore, the intent of this .

P a t A 4 C A Pia cr'ta-4m has not changed. ,

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.(2) A..y instance of personnel error, (5) Any event that alone could have equipcent failure, procedure violation, ~

prevented the fulfillment of the safety or discoveiy of design, analysis, function of structures or systems that fabrication, construction, or proce - are needed to --

dural inadequacies that alone could (1) Shut down the reactor and prevent the fulfillment of the safety maintain it in a ' safe'. shut-function of structures or systems down condition; .

that are needed to -- (ii) Remove residual heat; (i) Shutdown the reactor and (iii) Control the release of radio-maintain it in safe shut- active material, down condition; Such events may include one ur more per-(ii) Remove residual heat; sonnel errors, equipment failures, and/o (iii) Control the release of radio- discovery of design, analysis, fabricati-active material .

- construction,and/orproceduralinade-quacies.

Basis for Changes: .

The w:rding of this criterion has been changed to make it easier to read. The intent

. and scope of* the criterion 'have not been changed.

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3) Any event caused by a' failure, (6) Any event' where a single cause:

'sult, condition, or action that (i) Constituted an accident or

am'onstrates 'a nonconseryhtive- transient' initiator and aterdependence associated with defeated at least one train tssential structures, components, or channel of a system u1d systems, Essential structures, designed to ' mitigate that
smponents, and systems are those initiator.

acded to -- (ii) Simultaneously defeated one (i) Shutdown the reactor and train or channel in at least maintain it in safe shut- two independent systems down conditton; designed to -- -

(ii) Remove residual heat; (a) Shut down the reactor (iii) Control the release of and maintain it in a safe radioactive material. / shutdown ,conditidn (b) Remove residual heat (c) Control the release of radioactive material.

! asis for Changes:

9 ils criterion has been changed to clarify the intent of th phrase nonconservative

,terdependence." Numerous comment letters expressed difficulty in understanding what 711s phrase meant, '.so criterion has been changed to be more specific. The new criterion s narrower than the original criterion, because the term is specifically defined, but me intent is basically the same.

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4 (4) Any event for which p1' ant Technical (1) The completion of any nuclear plant vt-

' -Specifications require shutdown of the shutdown required by, plant Technical nuclear power plant or for which a plant Specifications or any operation with a Technical Specification Action Statement condition prohibited 'by the Technical is not met.. Specifications. Failure to comply with

. a Surveillance Requirement need not be reported as an LERuess 1 esms od orr.

e,oc or tw. c1st. ca.ne,ua emeixo in ms Basis for Changes: Ech'oe .

-The criterion has been reworded to more clearly define the events that must be reported.

-The scope is c' hanged slightly because it now requires the reporting of events "with a condition prohibited by the Technical Specifications" rather than events where "a plant Technical Specification Action Statement.js not met." This change a'ecomodates plants that do not have requirements that are specfically titled " Action Statements."

-Finally, the statement, " Failure to comply..." was added to the criterion. This Paomas qualif.ication had previously been in the Stat ::rt of Ccr.3ider:tien.

It was moved . -

to the regulation for clarity. -

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(5) Any event that results in the (2) Any event that resulted in the

' nuclear power plant not being in a nuclear power plant, including its controlled condition or that results

, principal safety barriers, being in an unanalyzed condition that seriously degraded or'in an unanalyzed significantly compromises plant condition that significantly compromises

, safety, plant safety. Such events include, but are not limited to:

i (5) Conditions not covered by the plant's operating and emergency procedures.

() High offgas at BWR air ejector monitor that exceeds the Technical Specification limits.

Wi (B) Indicatibn of increase. at '

PWRs greater than 0.1%

equivalent fuel failur'es since las t' determination.

iv (4) Coolant activity ' sample. that exceeded [echnical [pecificatior for* iodine spike.

Basis for Changes:

Eiamples of the types of events included in this criterion have been added to clarify the

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  • equirement. The scope and intent have not been substantatively changed.

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(6): Ar.yfact of nature, event, or act (3) Any natural. phenomenon or other by personnel that explicitly threatens external / ondition thatposes an actual the safety of the nuclear power plant or threat to the safety of the nuclear site personnel in the performance of power plant or to site personnel in the duties necessary for the safe operation performance of duties necessary for the of the plant, or the. security of special safe operation of the plant.-

nuclear material, including instances of sabetage or attempted sabotage. Threats of violence that are not substantiated .

by the licensee need not be reported.

Basis for Changes:

The criterion has been reworded to make it clear that it applies only to acts of nature (e.g., tornadoes) and external hazards (e.g., a railroad tank car e&plosion).

References to acts of sabotage have been removed because thef are covered by 10 CFR 73.71.

-Threats to personnel from internal hazards (e.g., radioactivity releases) are now -

covered' by a* separate criterion [50.73(a)(h)).

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7-(7) A:.y radioactive release that -

(t) Any event that threatened the safety l

! requi: es that evacuation of, a room of site personnel in the performance of or butiding, duties necessary,fdr, the safe operation of the nuclear power plant. Such events GAS include fires and toxic,or radioactive

releases.

Basis for Changes:

-This criterion has been reworded to include all internal physical hazards to personnel (e.g., electrical fires).

-h :dditie... in response to numerous comments, the scope has been narrowed sucfi that the hazard must -:ignifur.:tly hamper the ability of site personnel to perform safety-related activities.

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(8) Any radioactive effluent release (7 Any accidental, radioactive unplanned where - - or u controlled release where --

(1) The quantity of radioactive ( The quantity of radioactive materials in liquid or gaseous caterial contained in a liquid effluents released from the or gas storage tank exceeds the site exceeds the limits limi specified i the Technic specified in the Technical Specifi ations.

Specifications. (ii) With resp tt boiling water (ii) The' quantity of radioactive reactors on1 3 the rate of radi material contained in a liquid '

active mat rial n gaseous or gas storage tank exceeds waste tr sferred om the' the limits specified in the primary coolant syste to the Technical Specifications, gaseo s radwaste managem t (iii) With respect to boiling water .- system exceeds the limits s eci reactors only, the rate of f ed in the Technical Specifi radioactive material in gaseous cations.

waste transferred from tfie primary ,

coolant system ot the gaseous radwaste management system exceeds the limits specified in the Technical Specifications.

Basis for Changes: -

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JcctM- 50.73(a)(8) was in' tended to capture an event that causes the controlled release of a significant amount of radioactive material 1 to offsite areas. In addition, "significant" was based on the plant's l Technical Specification limits for the release of radioactive material. ,

l However, this section was deleted because the reporting of such events Pm.<.n.ua .: = C.. . . 3 Pan a.m

  • 010 01 read 1 adequately covered by3_0.73(a)(1) 5 and,20.405.
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(g) Any event for which the quantity of (3)tAny 8 radioactive release that radioactive materials released during caused vels of radiation or c cen-an unplanned offsite release is more trations f radio,ac'tive mater 1 (whether than 1 curie of radioactive material in or not invalving exposure o any indivi-liquid effluents, more than 150 curies dual) in an, ffsite area excess of the of noble gas in gasebus effluents, or following, whe averaged over a time more than 0.05 curies of radioiodine period of one hou :

in gaseous effluents. (a) 0.frem/hr total body dose

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for nobl gas releases via

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the sub.ersio or plume shine n..i~vn pathw y. p

\,.,,o u a .m (b) Two imes the com ned

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al radionuclides ex ept t itium and dissolved bl e ases. \

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Power reactor licensees shall report in accordance with this requirement in liqu

, , . . of 20.405(a)(S)., ,

Basis for Chances:

l This criterion has been changed to clarify the reporting of releases of radioactive material. The criterion i,s similar to 20.405 but places a lower threshold for.re. porting events a power reactors. The lower threshold is based on the significance of the breakdown of the licensees program necessary to have a release of.this size, rather than on the significance of the impact of the actual release.

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r (C-) For facilities' which have an instantaneous releagg r, ate technical ,

specification for noble ga' sis' derived by considering,that such a ,

rel' ease, if continued for one year, would reach the 10 CFR Part 20 ,

I value of 0.5 re:n per year in unrestricted areas; any release that exceeds 2 times that limit, when averaged over a time period of one -

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'! (b) For al1 other facilities; any hoble gas release that exceeds 2 times

.. (,g.. io cro.paa n , t . I:. h, t *' * )

the applicable concentrat ons jg of 10 CFR Part 20, Appendix B. Table 11 in unrestricted areas, when averaged *over a time period of one hour.

(c) Any liquid release that exceeds 2 times the limiting combined MPC

, (see 10 CFR Part. 20 Appendix B, Note 1) in the rece,1ving, water for all radionuclides except tritium.and dissolved noble, gases, when

.avefaged over a time period of one hour.

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