ML20248D214
| ML20248D214 | |
| Person / Time | |
|---|---|
| Issue date: | 03/04/1998 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-98-036, SECY-98-036-01, SECY-98-036-R, SECY-98-36, SECY-98-36-1, SECY-98-36-R, NUDOCS 9806020351 | |
| Download: ML20248D214 (15) | |
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RULEMAKING ISSUE (NEGATIVE CONSENT)
March 4, 1998 SECY-98-036 EDB:
The Commissioners FROM L. Joseph Callan Executive Director for Cpdrations
SUBJECT:
RULEMAKING TO MODITY EVENT REPORTING REQUIREMENTS FOR POWER REACTORS PURPOSE:
The purpose of this paper is to provide the staffs proposed rulemaking plan to modify the event reporting requirements in 10 CFR 50.72, "Immediate notification requirements for operating nuclear power reactors," and 10 CFR 50.73, " Licensee event report s:, tem."
BACKGROUND:
The current rules have been in place with little modification since 1983. Experience has shown a need for change in several areas to: (1) correct weaknesses in the current rules, including reducing the reporting burden associated with events of little or no safety significance, and (2)'
better align the rules with the NRC's current needs, including (a) obtaining information better related to risk and (b) reconsidering the required reporting times in relation to the need for prompt NRC action.
DISCUSSION:
Management Directive 6.3, "The Rulemaking Process," requires the rulemaking plan to address the following areas:
1.
Define the regulatory problem or issue to be resolved, and describe a preliminary concept of actions needed to resolve the problem.
I In summary, the current rules are in need of change in several areas to (1) correct weaknesses, including reducing the reporting burden associated with events of little or
['
l CONTACT:
Dennis P. Allison (DPA), AEOD/SPD/RRAB L -M - I t@
3 (301)415-6835 iU NM "4~
SECY NOTE:
To be made publicly 9906020351 990304 available when the final SRM j
is made available.
036 PDR t
The Commissioners 2
no safety sign lficance, and (2) better align them with the NRC's current needs, including (a) obtaining information better related to risk and (b)(EGnsidering the requ. ired reporting times in relation to the need for prompt NRC action. For example, there is some confusion and controversy about what must be reported as a condition outside the plant's design basis. In another example, the requirement to report actuation of any 1
engineered safety feature (ESF) sometimes requires reportirg for systems and/or
]
events with minimal risk significance. The staff will publish an advanced notice of j
proposed rulemaking (ANPR) and conduct a public workshop to obtain substantial public input before drafting a proposed rule to address these areas.
a I
These matters are discussed further in Attachment 1.
2.
Provide the Office of the General Counsel's (OGC) legal analysis of the rulerr '
l This analysis is provided below.
The Staff proposes to institute notice and comment rulemaking to address four specific areas of concem (set forth on p. 2 of the Attachment) and potentially address five other subject matters (set forth on pp. 2-3 of the Attachment).
The primary legal issue is backfitting. OGC has taken the position that changes to record-keeping and reporting requirements are not subject to the Backfit Rule, see SECY 93-086, p. 2 (April 1,1993), a position with j
which the Commission has not expressed its disagreement, Jag June 30, 1993 SRM. Since the proposed rulemaking is addressed solely to information co'iection and reporting requirements, the proposed rulemaking would not require a backfit analysis (although a regulatory analysis would have to be performed which addresses many of the same issues as a backfit analysis).
The second area of concem is with respect to overall increases in burden and compliance with the Paperwork Reduction Act of 1995. The Act requires the Director of OMB to set annual agency goals for reducing information collection burdens in accordance with the schedule and goals established in the Act. Thus, we support the Staff proposal to closely review the current, rather extensive data collection and reporting requirements in Sections 50.72 and 50.73 for the purpose of identifying information collections / reporting requirements which are unnecessary to achieving the agency's goals under a risk-informedW regulatory regime, so that they may be removed from Section 50.72 and 50.73 as part of this rulemaking.
f i A risk-informed regulatory approach retains elements of the deterministic regulatory regime, but adds on the risk-informed decisional criteria. Thus, removing information collection requirements which are unnecessary to a risk-informed regulatory regime should result in removal of information collection requirements which are not essential for either the current deterministically-based regulatory oversight or risk-informed regulatory oversight,
The Commissioners 3
3.
Provide the basis for believing that the rulemaking will be cost-effective and will meet backfit rule criteria, where appropriate.
The rutemaking is expected to be cost-offective because it is expected to improve the reactor event reporting process without a net increase in the industry's reporting burden or the NRC's review costs. The improvements will be obtained by (1) correcting weaknesses in the current rules, including reducing the reporting burden associated with events of little or no safety significance, and (2) better aligning the rules with the Nuclear Regulatory Commission's current needs, including (a) obtaining information better related to risk and (b) reconsidering the required reporting times in relation to the need for prompt NRC action. The backfit rule criteria do not apply because the scope of the rulemaking is limited to information gathering requirements.
4.
Indlcate wh:ther any known Agreement State problems exist.
The staff does not believe that any Agreement State problems exist because the proposed rule would only involve reports concerning events at power reactors.
5.
Identify supporting documents.
Supporting documents include:
a.
Draft regulatory analyses, to be prepared in conjunction with the proposed rules, b.
Draft regulatory guidance, to be prepared in conjunction with the rules, in the form of a revision to NUREG-1022.
l c.
Draft OMB clearance package to be prepared in conjunction with the proposed rules.
I 6.
Identify resources required to complete and implement the rulemaking.
In order to complete the rulemaking, the Office for Analysis and Evaluation of Operational Data (AEOD) estimates that it will devote about 2 FTE to the rulemaking effort during the next 24 months. OGC, the Office of Nuclear Reactor Regulation l
(NRR), the Office of Nuclear Regulatory Research (RES), and the four regional offices i
are expected to devote a total of about 2 FTE among them during the same period. The revised reporting requirements are not expected to increase the effort expended by the I
NRC in reviewing reactor events. Specific resource estimates will be addressed in the l
regulatory analyses which are yet to be performed.
1 7.
Indicate whether the sponsoring office recommends that the Executive Director for l
Operations (EDO) issue the rulemaking under the rulemaking authority delegated to the i
EDO by the Commission.
AEOD does not recommend that the EDO issue the resulting rule under the rulemaking authority delegated to the EDO by the Commission.
L
Q i
The Commissioners 4
8.
Identify the lead office staff and staff of participating offices, including the office representatives and an alternate, who will be involved in the rulemaking process.
AEOD will be the lead office in this rulemaking effort. Dennis Allison,415-6835, will serve as the AEOD project manager for these rules. The alternate will be Bennett Brady,415-6363.
Other offices, including NRR, RES, and the regional offices, will designate office representatives and allemates to provide input and review working drafts to help ensure that the rulemaking packages are ready for office concurrence when they are forwarded for that purpose.
9.
Identify, if appropriate, members of a steering group or working group.
The staff does not plan to use a formal steering group or working group format to develop the contemplated rules. The office representatives discussed above will constitute an !nformal working group to provide input and review working drafts to help ensure that the rulemaking packages are ready for office concurrence when they are forwarded for that purpose.
10.
Consider whether enhanced public participation should be employed in the rulemaking process and also describe special measures or procedures, to be employed (e.g., whether the rulemaking is a direct final rule or a negotiated rulemaking).
l The staff will publish an advanced notice of proposed rulemaking (ANPR) and conduct a public workshop to obtain substantial public input befe.e drafting a proposed rule.
11.
Include schedules for preparing supporting information and completing the proposal and comments process.
The current schedule is provided in Attachment 2.
. COORDINATION:
OGC has reviewed this paper and has no legal objections. The Office of the Chief Information Officer has reviewed the proposed rulemaking plan for information technology and information management implications and concurs in it. The resources to complete and implement this 3
l rulemaking have been coordinated with each office and are within each offices' respective budgets. The Office of the Chief Financial Officer has reviewed this paper for resource implications and has no objections.
f RECOMMENDATIONS-That the Commission note that, unless otherwise directed:
(1)
I intend to direct the staff to implement the proposed rulemaking plan ten working days after the date of this paper.
a e
The Commissioners 5
l (2)
In accordance with Management Directive 6.3, ADM will make this information available to the advisory committees, to the NRC staff through the internal NRC rulemaking bulletin board, and to the Agreement States through the external rulemaking bulletin board.
Attachments:
- 1. Regulatory issues and Preliminary Concept of Actions Needed 2 Schedule SECY NOTE:
In the absence of instructions to the. contrary, SECY will notify the staff on-Thursday, March 19, 1998, that the Commission, by negative consent, assents to the action proposed in this paper.
DISTRIBUTION:
Commissioners OGC OCAA OIG OPA OCA CIO CFO EDO REGIONS SECY
.n i_%
REGULATORY ISSUES AND PRELIMINARY CONCEPT OF ACTIONS NEEDED I
EXISTING REGULATORY FRAMEWORK:
The current event reporting requirements in 10 CFR 50.72, "Immediate notification requirements for operating nuclear power reactors," and 50.73, " Licensee event report system,"
are summarized in Tab!c 1 at the end of this attachment.<2)
Section 50.72 has been in effect, with minor modifications, since 1983. Its essential purpo se is
... to provide the Commission with immediate reporting of twelve types of significant events where immediate Commission action to protect the public health and safety may be required or where the Commission needs timely and accurate information to respond to heightened public concern."(81 As described in Table 1 at the end of this attachment, defined events are reported l
by telephone in the following time frames:
Declaration of an emergency class is reported immediately after notification of appropriate State or local agencies and not later than 1-hour after declaration.
Non-emergency,1-hour events are reported as soon as practical and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of occurrence.
Non-emergency,4-hour events are reported 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 occurrence.
Section 50.73 has also been in effect, with minor modification, since 1983. Its essential purpose is to identify "... the types of reactor events and problems that are believed to be significant and useful to the NRC in its effort to identify and resolve threats to public safety, it is designed to provide the information necessary for engineering studies of operational anomalies and trends and pattems analysis of operational occurrences. The same information can be l
used for other analytic procedures that will aid in identifying accident precursors."H) As described in the summary table at the end of this attachment, defined events are reported, in writing, within 30 days of discovery.
l ISSUES:
l Experience has shown a need for change in several areas to: (1) correct weaknesses in the current rules, including reducing the reporting burden associated with events of little or no 2 Further discussion and staff guidance on implementing the requirements is provided in NUREG-1022, Revision 1. Event Reporting Guidelines 10 CFR 50.72 and 50.73.
8 4S FR 39039, August.0,1983 d 48 FR 33851, July 26,1983 i
l safety significance, and (2) better align the rules with the NRC's current needs, including (a) obtaining information better related to risk and (b) reconsidering the required reporting times in relation to the need for prompt NRC action. Some examples of items under consideration for i
review are provided below.
l
- 1. One-hour time limit for reporting conditions outside the plant's design basis. Section 50.72 1
requires reporting a condition outside the plant's design basis within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of occurrence.
Many of these events involve engineering evaluations rather than operational occurrences.
These types of events are difficult to analyze and report on a short time frame and to the best of our knowledge, they have not involved an immediate need for NRC action to protect public safety or information to address heightened public concern.
- 2. Reporting of missed orlate equipment surveillance tests. Section 50.73 requires reporting a condition or operation prohibited by the plant's technical specifications (T.S.). This leads, in some cases, to reporting events that consist solely of missed or late surveillance tests.
That is, when the oversight is corrected and the equipment is tested it is still functional.
Tilese events have proven to be of little or no risk-significance when the equipment is found to be functional and no systematic breakdown of compliance with the T.S. is involved.
- 3. Reporting of events that result in actuation of any ESF. The current requirement is to report "Any event or condition that results in a manual or automatic actuation of any Engineered Safety Feature (ESF), including the Reactor Protection System (RPS) except when....."
This leads to confusion and variability in reporting because there are varying definitions of what constitutes an ESF. It also leads to reporting for systems of little risk-significance, such as reactor building closed cooling water system (RBCCW) isolation.
- 4. Reporting conditions outside the plant's design basis. There has been some confusion and controversy about the meaning of the requirement to report conditions outside the design basis of the plant. For instance, design basis information often provides both lower level and higher level design bases, and there is not general agreement about which level should trigger a report to the NRC. In one example, the Final Safety Analysis Report (FSAR) stated that a building design basis is as follows: pressure relief panels will relieve at about 45 psf in order to ensure that building pressure does not exceed its design pressure of 80 psf. When it was found that the panel would not relieve at 45 psf but 80 psf was still met, controversy ensued within the staff as well as between the staff and licensee regarding whether a report was required.
PRELIMINARY CONCEPT OF ACTIONS NEEDED TO RESOLVE THE ISSUES:
Generally,10 CFR 50.72 and 50.73 would be revised to (1) correct weaknesses in the current rules, including reducing the reporting burden associated with events of little or no safety significance, and (2) better align the rules with the NRC's current needs, including (a) obtaining information better related to risk and (b) reconsidering the required reporting times in relation to the need for prompt NRC action. The staff would publish an advanced notice of proposed rulemaking (ANPR) and conduct a public workshop to obtain substantial public input before drafting a proposed rule. Issues to be considered would include the following.
- 1. Whether and how the NRC should reviso the requirement to report ESF actuations in order to focus on risk-significant systems and/or events. For example, should the rule be revised I
L_________-------
o to drop systems that aie not risk-significant such as RBCCW isoir.'on? Should the rule be revised to add systems that are risk-significant such as reactor core isolation cooling (RCIC) and anticipated transient without scram (ATWS) mitigation systems?
- 2. Whether and how the NRC should revise the requirement to report conditions outside the design basis of the plant in order to make it clear what is to be reported. For example, should the rule be revised to state clearly whether the reporting requirement applies only to design bases in the FSAR? Also should the rule be revised to state clearly whether the report!ng requirement applies to the design objective or subordinate design basis information? Should the rule be revised to provide different required reporting times for various types of conditions outside the design basis?
- 3. Whether and how the NRC should revise the time limits for reporting various types of events to better correspond to the NRCs needs. For example:
(a) Should the requirement to report within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> be limited to events that involve either (1) the declaration of an emergency class or (2) an emergency deviation from the plant's T.S. authorized pursuant to 10 CFR 50.54(x)? (it currently includes several other types of events, such as initiation of a shutdown required by the plant's technical speci'ications. However, experience indicates that events significant enough to warrant activation of the NRC Operations Center involve emergencies.)
(b) Should the time limit for 4-hour reports be relaxed to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />?
(c) Should the time limit for reporting some types of 4-hour events be relaxed to 30 days?
- 4. Whether and how the NRC should revise other elements of the rules to better align them with the NRC's needs in view of its current programs, including Sie move tcward risk-informed regulation, and in view of other sources of information currently available such as Equipment Performance and Information Exchange (EPIX) and Safety System Performance Indicator (SSPl) data? For example, should the rule be revised to provide additional data regarding human performance to better support analysis of human error probabilities?
Should the rule be revised to provide additional data regarding the status of equipment during shutdown events to better support an assessment of the risk implications of these events? Should the rules be revised to provide additional data regarding external event initiators?
- 5. Whether and how the NRC should evaluate electronic forms of reporting that could more efficiently and with better consistency focus reports to capture safety-and risk-significant information.
8 Certain reports required by the LER rule, such as spurious actuation of an ESF, are used by the NRC staff to work around difficulties involved in using EPIX and SSPI data to develop estimates of reliability parameters.
Such reports would not be proposed for deletion.
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i SCHEDULE 2/27/98 Obtain EDO approval and forward rulemaking plan to Commission for negative cor sent 3/20/98 Provide ANPR to rulemaking group for comment 4/24/98 Provide ANPR to formal concurrence chain 5/29/96 Provide ANPR to CRGR and ACRS j
l 7/10/98 Complete briefing of CRGR and ACRS 7/24/98 Publish ANPR in FederalRegister 8/21/98 Conduct public workshop to discuss ANPR 9/18/98 Receive public comments on ANPR 10/16/98 Provide proposed rule package to rulemaking group for comment 11/27/98 Provide proposed rule package to formal concurrence chain 1/8/99 Provide proposed rule package to CRGR and ACRS 2/5/99 Complete briefing of CRGR and ACRS 2/26/99 Provide proposed rule package to Commission 4/2/99 Publish proposed rule E/2/99 Initial public comments due to OMB (with copies to NRC) 30 days after publication 6/1/99 Receive OMB approval,60 days after publication 6/15/99 Public comments due to NRC,75 days after publication
{
l' i i/
7/2/99 Provide final rule package to rulemaking group for comment 8/13/99 Provide final rule package to formal concurrence chain 9/17/99 Provide final rule package to CRGR and ACRS l
l l
11/5/99 Complete briefing of CRGR and ACRS i
l l
11/26/99 Provide final rule package to Commission l
1/7/00 Publish final rule l
l l
l l
i 2
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