NUREG-1022, Rev. 3, Supplement 2, Event Report Guidelines 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii) Final Report

NUREG-1022, Rev. 3, Supplement 2, Event Report Guidelines 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii) Final Report

ML24191A376
Person / Time
Issue date:	09/30/2024
From:	Paul Laflamme Office of Nuclear Reactor Regulation
To:
References
NUREG-1022 R3 S2
Download: ML24191A376 (1)

Text

NUREG-1022, Rev. 3 Supplement 2

Event Report Guidelines 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii)

Final Report

Office of Nuclear Reactor Regulation AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATIONS

NRC Reference Material Non-NRC Reference Material

As of November 1999, you may electronically access Documents available from public and special technical NUREG-series publications and other NRC records at the libraries include all open literature items, such as books, NRCs Library at www.nrc.gov/reading-rm.html. Publicly journal articles, transactions, Federal Register notices, released records include, to name a few, NUREG-series Federal and State legislation, and congressional reports.

publications; Federal Register notices; applicant, licensee, Such documents as theses, dissertations, foreign reports and vendor documents and correspondence; NRC and translations, and non-NRC conference proceedings correspondence and internal memoranda; bulletins and may be purchased from their sponsoring organization.

information notices; inspection and investigative reports; licensee event reports; and Commission papers and their Copies of industry codes and standards used in a attachments. substantive manner in the NRC regulatory process are maintained at NRC publications in the NUREG series, NRC regulations, The NRC Technical Library and Title 10, Energy, in the Code of Federal Regulations Two White Flint North may also be purchased from one of these two sources: 11545 Rockville Pike

1. The Superintendent of DocumentsRockville, MD 20852-2738

U.S. Government Publishing Office These standards are available in the library for reference Washington, DC 20402-0001 use by the public. Codes and standards are usually Internet: https://bookstore.gpo.gov/ copyrighted and may be purchased from the originating Telephone: (202) 512-1800 organization or, if they are American National Standards, Fax: (202) 512-2104 from

2. The National Technical Information ServiceAmerican National Standards Institute 5301 Shawnee Road 11 West 42nd Street Alexandria, VA 22312-0002 New York, NY 10036-8002 Internet: https://www.ntis.gov/ Internet: www.ansi.org 1-800-553-6847 or, locally, (703) 605-6000 (212) 642-4900

Legally binding regulatory requirements are stated only in laws; NRC regulations; licenses, including technical A single copy of each NRC draft report for comment is specifications; or orders, not in NUREG-series publications.

available free, to the extent of supply, upon written The views expressed in contractor prepared publications in request as follows: this series are not necessarily those of the NRC.

The NUREG series comprises (1) technical and Address: U.S. Nuclear Regulatory Commission administrative reports and books prepared by the staff Office of Administration (NUREG-XXXX) or agency contractors (NUREG/CR-XXXX),

Digital Communications and Administrative (2) proceedings of conferences (NUREG/CP-XXXX),

Services Branch (3) reports resulting from international agreements Washington, DC 20555-0001 (NUREG/IA-XXXX),(4) brochures (NUREG/BR-XXXX), and E-mail: Reproduction.R esource@nrc.gov (5) compilations of legal decisions and orders of the Facsimile: (301) 415-2289 Commission and the Atomic and Safety Licensing Boards and of Directors decisions under Section 2.206 of the NRCs regulations (NUREG-0750), (6) Knowledge Management Some publications in the NUREG series that are posted prepared by NRC staff or agency contractors (NUREG/KM-at the NRCs Web site address www.nrc.gov/reading-rm/ XXXX).

doc-collections/nuregs are updated periodically and may DISCLAIMER: This report was prepared as an account of work differ from the last printed version. Although references to sponsored by an agency of the U.S. Government. Neither the material found on a Web site bear the date the material U.S. Government nor any agency thereof, nor any employee, was accessed, the material available on the date cited makes any warranty, expressed or implied, or assumes any may subsequently be removed from the site. legal liability or responsibility for any third partys use, or the results of such use, of any information, apparatus, product, or process disclosed in this publication, or represents that its use by such third party would not infringe privately owned rights.

NUREG-1022, Rev. 3 Supplement 2

Event Report Guidelines 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii)

Final Report

Manuscript Completed: September 2024 Date Published: September 2024

Prepared by:

P. LaFlamme

Office of Nuclear Reactor Regulation

ABSTRACT

NUREG-1022, Revision 3, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, issued in January 2013, contains guidelines that the staff of the U.S. Nuclear Regulatory Commission (NRC) considers acceptable for use in meeting the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.72, Immediate notification requirements for operating nuclear power reactors, and 10 CFR 50.73, Licensee e vent report system. This supplement clarifies the guidance in section 3.2.4, Degraded or Unanalyzed Condition, of NUREG -1022, Revision 3, which contains general guidance for event reporting under 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii).

The regulations in 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii) require reports for any event or condition that results in either of the following:

• the condition of the nuclear power plant, including its principal safety barriers, being seriously degraded

• the nuclear power plant being in an unanalyzed condition that significantly degrades plant safety

In developing Supplement 2 to NUREG-1022, Revision 3, the NRC evaluated data on submitted and retracted event notifications and held a public meeting on August 9, 2023, to discuss this section 3.2.4 of NUREG-1022 with stakeholders. Supplement 2 provides updated guidance for nuclear power reactor licensees and can be used for evaluating and reporting d egraded and unanalyzed conditions as described in 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii). The specific guidance included in this supplement supersedes t he guidance found in section 3.2.4 of NUREG-1022, Revision 3.

Paperwork Reduction Act Statement

This NUREG provides voluntary guidance for implementing the mandatory information collections in 10 CFR Part 50 that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et. seq.). These information collections were approved by the Office of Management and Budget (OMB), approval number 3150-0011. Send comments regarding this information collection to the FOIA, Library and Information Collections Branch (T6-A10M), U.S.

Nuclear Regulatory Commission, Washington, DC 20555- 0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the OMB reviewer at: OMB Office of Information and Regulatory Affairs (3150-0011), Attn: Desk Officer for the Nuclear Regulatory Commission, 725 17th Street, NW Washington, DC 20503.

Public Protection Notification

The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the document requesting or requiring the collection displays a currently valid OMB control number.

Congressional Review Act Statement

NUREG-1022, Revision 3, Supplement 2, is a rule as defined in the Congressional Review Act (5 U.S.C. 801-808). However, the Office of Management and Budget has not found it to be a major rule as defined in the Congressional Review Act.

iii

TABLE OF CONTENTS

ABSTRACT............................................................................................................................... iii

1. INTRODUCTION..............................................................................................................1

2. SPECIFIC REPORTING GUIDELINES............................................................................3

3. CONCLUSION.................................................................................................................9

v

1. INTRODUCTION

This document provides guidance on the reporting requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.72, Immediate notification requirements for o perating nuclear power reactors, and 10 CFR 50.73, Licensee event report system, specific to the criteria in 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii) for degraded and unanalyzed conditions.

1.1 Background

In August 2018, the Nuclear Energy Institute submitted a petition to amend 10 CFR 50.72. In 2021, the commission ers of the U.S. Nuclear Regulatory Commission (NRC) directed the NRC staff to pursue rulemaking to evaluate the immediate notification requirements for nonemergency events in 10 CFR 50.72(b) (Agencywide Documents Access and Management System Accession No. ML21209A947). As part of this rulemaking effort, the NRC determined that clarifications to the guidance in section 3.2.4, Degraded or Unanalyzed Condition, of NUREG-1022, Revision 3, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, issued in January 2013, could address part of the concerns identified in the petition. To expedite this process, the NRC developed Supplement 2 to NUREG-1022, Revision 3, to address stakeholder concerns outside of the rulemaking process.

1.2 Revised Reporting Guidelines

The purpose of Supplement 2 to NUREG-1022, Revision 3, is to incorporate clarifications and updates to the existing guidance in section 3.2.4. This supplement supersedes section 3.2.4 of NUREG-1022, Revision 3.

1

2. SPECIFIC REPORTING GUIDELINES

Section 3.2.4 of NUREG-1022, Revision 3, relates to a degraded or u nanalyzed condition, as defined in the regulations as follows:

10 CFR 50.72(b)(3)(ii) 10 CFR 50.73(a)(2)(ii)

Any event or condition that results in: Any event or condition that resulted in:

(A) The condition of the nuclear power (A) The condition of the nuclear power plant, including its principal safety plant, including its principal safety barriers, being seriously degraded; orbarriers, being seriously degraded; or

(B) The nuclear power plant being in an (B) The nuclear power plant being in an unanalyzed condition that significantly unanalyzed condition that significantly degrades plant safety. degraded plant safety.

A licensee event report (LER) is required under 10 CFR 50.73(a)(2)(ii) for a seriously degraded principal safety barrier or an unanalyzed condition that significantly degrades plant safety. If such an event or condition is not reported under 10CFR 50.72(a), (b)(1), or (b)(2), then the licensee must report the event or condition through an event notification under 10 CFR 50.72(b)(3). Sections 50.72(a)(1)(ii) and 50.73(a)(1) require e vent notifications and LERs, respectively, if a d egraded or unanalyzed condition occurs within 3 years of the date of discovery of the condition, even if the event is not ongoing at the time of discovery.

Licensees reporting under 10 CFR 50.72 and 10 CFR 50.73 for events involving design basis functions that are also associated with Risk-Informed Safety Class (RISC)- 1 or RISC-2 structures, systems, and components (SSCs) for licensees that receive NRC authority to use 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, are also required to report under 10 CFR 50.69(g) for events involving RISC - 1 or RISC-2 SSCs that perform functions credited for beyond design basis mitigation. Reporting events involving RISC - 1 or RISC-2 that perform credited beyond design basis functions is distinct from, and in addition to, events involving credited design basis functions for RISC-1 or RISC-2 SSCs. The criteria in 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii) do not apply to RISC-3 or RISC-4 SSCs for licensees that are authorized to use 10 CFR 50.69.

2.1 Time of Discovery

Conditions may arise under which it is not immediately apparent that a degraded or unanalyzed condition that requires reporting under this criterion exists. When these conditions are identified, further evaluation may be necessary to determine whether the condition resulted in a seriously degraded principal safety barrier or unanalyzed condition that significantly degraded plant safety. Attempts to determine whether such a condition exists, starting from the time of occurrence of the condition for the purposes of reporting, may lead to more notifications and subsequent retractions for these reports than other reporting criteria, placing an unwarranted burden on the licensee and the NRC.

To provide clarity on event notifications under 10 CFR 50.72(b)(3)(ii) and LERs required under 10 CFR 50.73(a)(2)(ii), the term discovery is defined as either of the follow ing:

3

• the moment when a degraded or unanalyzed condition occurs, such as those discussed in the examples below, or is found to have occurred; or

• if the existence of a seriously degraded principal safety barrier or unanalyzed condition that significantly degrades plant safety cannot be readily determined when it occurs or when it is found to have occurred, and additional evaluation is needed, then the moment when the evaluation that supports the existence of such a condition is completed.

For event notifications under 10 CFR 50.72(b)(3)(ii) and LERs under 10 CFR 50.73(a)(2)(ii), an initial analysis of a previously unanalyzed condition could demonstrate reasonable expectation of operability or functionality for all impacted equipment or safety systems. Further analysis could result in the discovery of a degraded or unanalyzed condition. In these situations, for purposes of reportability, the time of discovery would be the moment when the revised analysis concluded a degraded or unanalyzed condition existed, regardless of the timing or outcome of any prior evaluation. Such evaluations should be performed commensurate with the potential safety significance of the underlying issue, given the information available absent the evaluation.

2.2 Examples

A: A Nuclear Power Plant, Including Its Primary Safety Barriers, Being Severely Degraded

This criterion pertains to issues like material problems (e.g., metallurgical or chemical) that result in an abnormal degradation of or stress on the primary safety barriers, such as the fuel cladding, reactor coolant system pressure boundary, or containment. Abnormal degradation may necessitate corrective action to restore the barriers functionality, as described in some of the examples below, while abnormal stress on a barrier might arise from an unplanned transient, as seen in example (4) below. The following are five examples of reportable events and conditions:

1. Fuel cladding failures that exceed expected values, unique or widespread cladding failures, or failures caused by unexpected factors.

2. Welding or material indications in the primary coolant system that do not meet the acceptance standards defined in American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code, SectionXI, Rules for Inservice Inspection of Nuclear Power Plant Components, TableIWB-3410-1, Acceptance Standards and the respective Tables in IWB-3500, Acceptance Standards.

3. Degradation of steam generator tubes that is deemed serious if the tubes fail to meet the performance criteria outlined in the plant-specific technical specifications (TS) for steam generator tube integrity. When one or more steam generator tubes meet the tube repair criteria and have not been plugged or repaired in accordance withthe steam generator program, they are not considered to be severely degraded as long as structural integrity and the accident-induced leakage performance criteria in the plant-specific TSs are met.

4. Low-temperature overpressure transients violating pressure-temperature limits derived from Appendix G, Fracture Toughness Requirements, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities (e.g., TS pressure-temperature curves).

4

5. Loss of containment function or integrity, including containment leak rate tests in which the total containment as-found, minimum-pathway leak rate exceeds limits in the facilitys TS.

B: Unanalyzed Condition Significantly Affecting Plant Safety

In the preambles to the 1983 final rules amending 10 CFR 50.72 and establishing 10 CFR 50.73, the Commission stated the following regarding 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii):

The Commission recognizes that the licensee may use engineering judgment and experience to determine whether an unanalyzed condition existed. It is not intended that this paragraph apply to minor variations in individual parameters, or to problems concerning single pieces of equipment. For example, at any time, one or more safety-related components may be out of service due to testing, maintenance, or a fault that has not yet been repaired. Any trivial single failure or minor error in performing surveillance tests could produce a situation in which two or more often unrelated, safety-grade components are out-of-service.

Technically, this is an unanalyzed condition. However, these events should be reported only if they involve functionally related components or if they significantly compromise plant safety.1

The following are examples of reportable unanalyzed events and conditions that could significantly compromise plant safety:

1. The accumulation of voids that could impede the adequate removal of heat from the reactor core, especially under natural circulation conditions. The significance of this case is generally tied to the inability to perform a required safety function. However, t he accumulation of voids previously deemed not safety significant through analysis does not need to be reported.

2. Voiding in instrument lines leading to erroneous indications that could mislead operators about the actual plant condition.

3. The discovery that a system required to meet the single-failure criterion would have failed to meet its safety function.

4. Fire barriers are found to be missing, resulting in insufficient separation for redundant safe-shutdown trains. Conversely, if a fire wrap is missing from one safe-shutdown train but another is available in a different fire area, providing the required separation for safe-shutdown trains, the event need not be reported.

5. Multiple functionally related safety-related components that may be in different systems are out of service that could prevent the fulfillment of a safety function.

1 48 FR 39039, 39042 (August 29, 1983), and 48 FR 33850, 33856 (July 26, 1983).

5 2.2.1 Additional Examples

(1) Failures of Reactor Fuel Rod Cladding Discovered during Fuel Assembly Testing

Radiological data for a specific pressurized water reactor indicated that numerous fuel rods had experienced failures during the initial months of operation. Projections ranged from 6 to 12 failed rods. The end-of-cycle reactor coolant system iodine-131 activity averaged 0.025 microcuries per milliliter. After the end-of-cycle shutdown, iodine-131 levels spiked to 11.45 microcuries per milliliter. The cause was a significant number of failed fuel rods. Inspections revealed that out of the total 157 fuel assemblies, 136 contained failed fuel (approximately 300 fuel rods had through-wall penetrations), well beyond the expected number of failures. The defects were typically the size of a pinhole. Fuel cladding failures resulted from long-term fretting caused by debris that became lodged between the lower fuel assembly nozzle and the first spacer grid.

This penetration of the stainless -steel fuel cladding was due to machining debris from thermal shield support system repairs during the previous refueling outage.

The event wa s reportable because cladding failures exceeded anticipated values and were unique or widespread.

(2) Degradation of the Reactor Coolant System Pressure Boundary Due to Corrosion of a Control Rod Drive Mechanism Flange

During a hot shutdown, six control rod drive mechanism (CRDM) reactor vessel nozzle flanges were identified as leaking. Subsequently, one of the flanges was found to be eroded and pitted.

While removing the nut ring from beneath the flange, the licensee discovered that approximately 50 percent of one of the nut ring halves had corroded away, with two of the four bolt holes in the corroded nut ring half degraded to the point of no bolt-thread engagement. An inspection of the flanges and spiral-wound gaskets removed from between the flanges revealed that the leaks resulted from the gradual deterioration of the gaskets due to aging. A replacement CRDM was installed, and the gaskets on all six CRDMs were replaced with graphite-type gaskets of a new design.

The event wa s reportable because there was a material defect in the primary coolant system and degradation of the reactor coolant system pressure boundary that was not acceptable under ASME Boiler and Pressure Vessel Code,Section XI.

(3) Reactor Fuel Rod Cladding Degradation Detected during Fuel Sipping Operations

With the plant in cold shutdown, fuel sipping operations appeared to indicate that a significant portion of cycle-2 fuel, type LYP, had failed, with four confirmed and 12 potential fuel leakers identified. The potential fuel leakers had only undergone sipping once before an emergency notification system notification was made. The licensee sought assistance from the fuel vendor to evaluate this issue. An event notification would not be required at this time because further analysis was needed to determine whether a degraded or unanalyzed condition existed, and therefore time of discovery would be delayed based on the second definition for time of discovery at the beginning of section 2.1. Additional sipping operations and subsequent evaluation by the licensee s reactor engineering department, with vendor assistance, concluded that no additional fuel failures had occurred. The abnormal readings associated with the potential fuel leakers were attributed to fission products trapped in the crud layer.

The event was not reportable because further analysis showed that the fuel cladding was not severely degraded.

6 (4) Additional Clarification for Events Not Required to B e Reported

Licensees are not required to report an event pursuant to this criterion if the event results from a shared dependency among trains or channels that is a natural or expected consequence of the approved plant design, or normal and expected wear or degradation. For example, the failure due to normal and expected wear of components identified as acceptable in the licensee's maintenance program would not be reportable under this criterion.

7

3. CONCLUSION

Section 3.2.4 of NUREG-1022, Revision 3, contains general guidance for event reporting under 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii). The existing guidance in NUREG -1022, Revision 3, section 3.2.4 is superseded by this supplement.

Although an event or condition might not require a licensee report under 10 CFR 50.72 or 10 CFR 50.73, other regulatory requirements may necessitate a report.

9

NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER (12-2010) (Assigned by NRC, Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers, if any.)

BIBLIOGRAPHIC DATA SHEET NUREG 1022, Revision 3

(See instructions on the reverse) Supplement 2

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

MONTH YEAR Event Report Guidelines 10 CFR 50.72(b)(3)(ii) and 50.73(a)(2)(ii) September 2024

Final Report 4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT Paul R LaFlamme Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U. S. Nuclear Regulatory Commission, and mailing address; if contractor, provide name and mailing address.)

Division of Reactor Oversight Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above", if contractor, provide NRC Division, Office or Region, U. S. Nuclear Regulatory Commission, and mailing address.)

Same as above

10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 words or less)

NUREG-1022, Revision 3, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, issued in January 2013, contains guidelines that the staff of the U.S. Nuclear Regulatory Commission (NRC) considers acceptable for use in meeting the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.72, Immediate notification requirements for operating nuclear power reactors, and 10 CFR 50.73, Licensee event report system. This supplement clarifies the guidance in section 3.2.4, Degraded or Unanalyzed Condition, of NUREG 1022, Revision 3, which contains general guidance for event reporting under 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii).

The regulations in 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii) require reports for any event or condition that results in either of the following:

• the condition of the nuclear power plant, including its principal safety barriers, being seriously degraded

• the nuclear power plant being in an unanalyzed condition that significantly degrades plant safety

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT NUREG-1022 unlimited Degraded 14. SECURITY CLASSIFICATION Unanalyzed (This Page)

Notification unclassified Reportability (This Report) unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (12-2010)

,_,p.R REG(/

r:, (1

/.. "'011.,_

'=,,: '6 t/) I ' :* s:::

• • ff

'("'4: ',,** \\'* ':-,.(,_;

/) o

• • • 1(-i' UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, DC 20555-0001 OFFICIAL BUSINESS X@J f* D**1n

@NRCGOV NUREG-1022, Rev. 3 Event Report Guidelines September 2024 Supplement 2, Final 10 CFR 50.72(b)(3)(ii) and 10 CFR 50.73(a)(2)(ii)