ML20235G457
| ML20235G457 | |
| Person / Time | |
|---|---|
| Issue date: | 04/22/1986 |
| From: | Jennifer Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Heltemes C NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| Shared Package | |
| ML20235G382 | List: |
| References | |
| FOIA-87-377 NUDOCS 8707140260 | |
| Download: ML20235G457 (9) | |
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MEMORANDUM FOR:
C. J. Heltemes, Jr. , Director .
Office for Analysis and Evaluation of Operational Data FROM:
John G. Davis, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
ABNORMAL OCCURRENCE REPORT TO CONGRESS FOR FIRST QUARTER CY 1986 Pursuant to the request in Section 'I.A.4. of your memorandum of April 7,1986, NMSS provides the enclosed write-up of the follow-up actions being taken by Headquarters offices in response to the Sequoyah Fuels UF6 cylinder accMent.
We have no other abnormal occurrence items in response to Enclosure 2 of your memorandum.
(Signed) John G. Davie John G. Davis, Director Office of Nuclear Material Safety and Safeguards
Enclosure:
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0FFICIAL RECORD COPY 8707140260 870708 l PDR FOIA l CORDON 67-377 PDR
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SEQUOYAH FUELS ACCIDENT - FOLLOWUP ACTIONS
'As a result of the Sequoyah Fuels accident, a Lessons Learned Task Group has been formeo and is currently interviewing appropriate members of the NRC staff, Sequoyah Fuels Corporation, State of Oklahoma, and local authorities. A Lessons Learned Report is scheduled to be completed in May.
The staff is also compiling a list of followup items that need to be considered and addressed. Additional items are anticipated from the Lessons Learned Task-Group and other sources. Upon completion of the list, action items will be grouped into categories and priorities assigned. Tasks will be undertaken based on priorities and resource requirements.
In the meantime, the staff is moving ahead on a number of near-term follow-on actions, such as: (1) verification by NRC of existing emergency phone numbers; (2) requiring licensees to verify quarterly emergency numbers and availability of emergency response assistance; (3) informing DOE and other licensees, who are conducting operations involving UF , of the accident and providing relevant reports;and(4)establishingastudyhrouptoconductanindependentreviewof the materials licensing and inspection programs.
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Contact:
- 1. T. Crow x74100
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DIVISION OF SAFEGUARDS ' GUIDELINES ON ABNORMAL OCCURRENCE REPORTING Objectives These guidelines are intended to help Safeguards staff who review events for possible reporting as abnormal occurrences. They supplement Manual Chapter 0212 (" Abnormal Occurrence Reporting Procedures"). To make effective an Abnormal Occurrence Reporting System, the identification of possible abnonnal occurrence (or other related items) should be routinely considered in the general course of.
NRC business, i.e., including such staff licensee interaction as routine staff visits to licensee site, Regulatory Effectiveness Reviews,. License conditions, revision / upgrading,etc.
Events are selected. as abnormal occurrence ( A0s) based on criteria which were promulgated in an NRC policy statement, published in the Federal Register on February 24, 1977 (42FR 10950). (See Attached.)
As stated therein, an event will be considered an abnormal occurrence if it involves a major reduction in the degree of protection of public health and safety. Such an event would involve a moderate or more severe impact on the public health o safety and could include but need not be limited to:
- 1. Moderste exposure to, or release of, radioactive material licensed by o otherwise regulated by the Commission;
- 2. Major degradation of essential safety-related equipment; or
- 3. Major deficiencies in design, construction, use of, or management controls for licensed facilities or material.
4 Any substantial breakdown of physical security or material control (i.e., access
-control, containment, or accountability systems) that significantly weakened the ,
protection against theft, diversion or sabotage.
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- 5. Serious deficiency in management or procedural controls in major areas: recurring incidents, and incidents with implications for similar facilities (generic inci-dents), which create major safety concerns.
- 6. ' Series of events (where individual events are not of major importance), recurring incidents, and incidents with implication for similar facilities (generic inci-dents), which create major safety concerns.
Safeguards-related occurrences (incidents / events), when deemed suitable for A0 reporting are most likely to be classified under items 3, 4, 5, or 6 above.
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Reporting Requirements a.nd A0 Criteria AE00 published a handbook on December 14, 1984 on the application of this Abnormal Occurrence Criteria. This handbook states that the mechanics of reporting and the authority for such are as follows:
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-2 From the time the incident / event was noted as an A0 ' candidate', Office roview and comment should be submitted within five working days for individual AO's and 10 working days from the date of the AE0D requested (for inclusion in)
The Quarterly A0 Reports. This is_ a legal requirement stipulated under section 208 of the Energy Reorganziation Act of 1974 (Public Law 93-438, 42 U.S.C. 5848) which requires the NRC submit to the Congress each quarter a report for that period listing any abnormal occurrences at or associated with any facility which is licensed or otherwise regulated by the NRC.
The Division of Safeguards report shall contain:
- 1. the date and place of each occurrence;
- 2. the nature and probable consequence of each occurrence;
- 3. the cause or causes of each; and
- 4. any action taken to prevent reoccurrence.
The Commission shall also provide as wide dissemination to the public of the information specified in items (1) and (2) above as reasonably possible within fifteen days of its receiving infonnation about each abnormal occurrence and shall provide a wide dissemination to the public as reasonably possible of the information specifiedpn items (3) and (4) above as soon as such information becomes available to it Included also are Other Related items not included in the A0 Quarterly Report but discussed in the Commission Paper that forwards the A0 Quarterly Report to the Com-mission for review and approval. Included in the A0 Quarterly Report are Other Events of Interest, which though determined by NRC not to be of public health significance, may be perceived as such by the public. Guidelines for selection and processing procedures for these events are given in Part III of Appendix NRC Manual Chapter 0212. The following are the most likely events that would involve safeguards. Some A0 examples are explicit in defining reporting thresholds. Other examples are more general . This is done to allow flexibility in determining deportability of events.
The General A0 criterion, and its General subcriteria are:
o Events involving a major reduction in the degree of protection of the public health or safety. Such an event would involve a moderate or more severe imp'act on the public health or safety and could include but need not be limited to:
o Major deficiencies in design, construction, use of or management controls for licensed facilities or material.
1/ See Secy 76-471, Sept.10,1976 and the NRC Policy Statement (Implementing Section 208), in Federal Register (42 FR 10950) Feb. 24,1977.
o Any loss of licensed cterial in such quantities and under such circumstances that substantial hazard may result to persons in unrestricted areas.
o A substantiated case of actual or attempted theft or diversion of licensed material or sabotage of a facility.
o Any substantiated loss of special nuclear-material or any substantiated inventory discrepancy which is judged to be significant relative to normally expected performance and which is judged to be caused by theft or diversion or by substantial breakdown of the accountability system.
o Any substantial breakdown or physical security or material control (i.e.,
access control, containment, or accountability systems) that significantly weakened the protection against theft, diversion or sabotage.
o Serious deficiency in management or procedural controls in major. areas.
o Series of events (where individual events are not of major importance),
recurring incidents, and incidents with implications for similar facilities (generic incidents), which create major safety concern.
The intent is to report events where the potential for theft or diversion of licensed material, or for sabotage of the f acility, has been substantially in-creased. Where actual or attempted theft, diversion, or sabotage is involved, the last three listed above would generally be applicable, i A substantial breakdown of physical or material control can generally be defined in terms of the licensee reporting requirement of 10 CFR 73.71 (" Reports of unaccounted-for shipments, suspected thefts, unlawful diversion, radiological (
sabotage, or events which significantly threaten or lessen the effectiveness of I safeguards"). Any of these events which must be reported to the NRC within 24 nours should be given careful consideration for A0 Reporting, e.g., as shown <
earlier, "Any substantial breakdown of Physical Security.... that significantly ,
weakened the protection...." pg 3. item 4, is a criteria set for A0 reporting 1 that falls within the As stated therein there are five l categories of events 2JO CFR to be 73.91toreference.
reported the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l
Reporting Time l Event- to NRC i l
- 1. Explicit Threat. Within I hr. i
- 2. Major loss of physical secruity effectiveness. Within 1 hr.
2_/ The specific definitions can be found within 10 CFR 73.71
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- 3. Potential Threat. Within 24 hrs.
4 Major loss of physical security effectiveness which has been properly compensated. Within 24 hrs.
- 5. Moderate loss of physical security effectiveness. Within 24 hrs.
The following examples, or equivalent, show what would be candidates for reporting as A0s:
(1) An unauthorized person reaching a vital area is generally reportable.However, this example requires some judgement in implementation based upon the circum-stances. For instance, if an NRC inspector or security personnel deliberately attempted to test the security system and succeeded, the question would' be whether such an act could reasonably be expected to succeed by an unofficial person.Another instance would be a case where a driver and truck were admitted-to the facility (vital 6rea or not) and later another person (s) was found in the truck. The question would be whether criminal intent was involved, and/or whether the truck and pepple were under constant surveillance. A futher instance would be if an emergency vehicle were admitted to the facility (vital area or not). The question again would be whether criminal intent was involved and/or whether the vehicle and people were under constant surveillance.
(2) Any unauthorized person breaching any part ,of the facility protected by guards or mechanical / electronic surveillance would be reportable if it can be reasonably assumed that evil / criminal intent was involved.
(3) Bomb threats would not generally be reportable. However, if an actual explosive device is found, or there is evidence that an attempt was actually made to plant a bomb, the event would be reportable.
(4) If a guard strike left the facility inadequately protected, or if a break-down of the surveillance system left the facility without an adequate backup for reporting.
(5) If the accountability systems are shown to be inadequate against theft or diversion of licensed material, the event would be reportable. However, if
' licensed material beyond acceptable limits is actually missing and it is strongly suspected to have been stolen or diverted, it would be reportable under examples 1 or 6, General Subcriteria, (pg 4) abova.
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SAFEGUARDS EVENTS REPORTED TO CONGRESS AS ABNORMAL OCCURRENCES
- 1. Nuclear Material Inventory Anomaly December 1,1975 NFS, Inc., Erwin, TN A.0. Report Number: N. A.
A.O. Reporting Criterion: not stated. AE0D suggests it was a statistically significant variance from Lemuf.
- 2. Accumulated Nuclear Material Inventory Anomaly April 1974 through August 1976 Babcock & Wilcox Co., Apollo, PA A.0. Report Number: 76-12 A.0. criterion employed at the time of the report: CUM MUF. Reported on basis of problems in accounting and measurement (no specific category given).
3.* Breach of Physical Security' Syet.vn April 18-19, 1977 Fort St. Vrain Nuclear Generating Station Platteville, C0 A,0, Report Number: 77-2 A.0. Reporting Criterion: breach of physical security' system.
- 4. Extortion Attempt Involving Alleged Thef t of Licensed Material Janua ry 29, 1979 General Electric Company, Wilmington, NC A.0. ReportNumber: 79-4 A.0. Reporting Criterion: extortion attempt involving alleged theft of licensed material. '
5.* Damage to New Fuel Assemblies May 7, 1979 Surry Power Station, Surry County, VA A.0. Repor t Number: 79-6 A.0. Reporting Criteria: substantiated case of actual or attempted' theft, diversion, or sabotage. Conviction obtained for sabotage.
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' 6. Unresolved Nuclear Material Inventory Difference September 17, 1979 Nuclear Fuel Services, Erwin, TN
.A.O. Report Number: 79-10' A.O.ReportChiteria: substantiated inventory discrepancy.
s 7.* Misalignment of: High Speed. Safety Injection Isolation' Valve June 6,1981 Beaver Valley Power Station, Beaver Valley, PA A.O. . Report Number: 81-3 <
T A .O. Reporting Criterion: major degradation of; essential safety equipment
- 8. ' Degradation of Material Access Area Barriers May 22, 1984. Nuclear Fuel Services, Erwin, TN A.0. Reporting Number: 84-1 2 A.O. Reporting Criterion: serious deficiency. in management .or procedural-controls which lessened the- overall effectiveness of the security. barrier.
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- CEvents involving. nuclear reactors 1
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A0 REFERENCES
- 1. Application of the Abnonnal Occurrence Criteria and Associated Examples AE0D Draft Aug. 1984.
- 2. Manual Chapter 0212, Abnormal Occurrence Reporting Procedure July 14, 1984
- 3. Energy Reorganization Act of 1974, Section 208 Abnormal Occurrence Reports, (pg.139) P.L.93-433 Enacted Oct. 11, 1974 (88 Stat 1233).
- 4. Abnormal Occurrence Reports, Implementation of Section 208, Energy Reorgani-zation Act of 1974; Policy Statement Federal Register, Vol 42, No. 37, February 24, 1977, pgs. 10950-52.
- 5. Regulatroy Effectiveness Review (Unclassified) from Attachment 1, R.E.R.
.l?NC (Montville) (4 pgs.) undated (SGFF).
- 6. A Program Plan for Regulatory Effectiveness Reviews of Nuclear Power Reactors (27 pgs.) undated (SGPR).
- 7. SECY-76-471, Abnormal Occurrence Criteria, Sept. 10, 1976 NRC.
- 8. SECY-78-460A, Quarterly Abnonnal Occurrence Reports to Congress - Guidelines for Appendix C Items Dec.1,1978 NRC.
- 9. SECY-84-60, Staff Guidance for Selection of Medical Misadministration Events for Abnormal Occurrrence Reporting - Revised Feb. 3,1984 NRC.
- 10. Safeguards Events Reported to Congress as Abnormal Occurrences (SGLP)
(Gleaned from NUREG-0900, Report to Congress on Abnormal Occurrences) NRC.
- 11. Program Plan and Procedures for Regulatory Effectiveness Reviews of Fuel Cycle f acilities Feb. 13, 1984 (SGPR).
- 12. Handbook on Application of the Abnormal Occurrence Criteria and Examples, AE0D, December 14, 1984.
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