ML20128B592
| ML20128B592 | |
| Person / Time | |
|---|---|
| Issue date: | 12/10/1991 |
| From: | Jordan E NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Fraley R Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML19341G314 | List: |
| References | |
| FRN-57FR28642, RULE-PR-50 AD03-1-009, AD3-1-9, NUDOCS 9302030106 | |
| Download: ML20128B592 (30) | |
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! k UNITED STATES NUCLEAR RECULATORY COMMISSION /OM g WASHING T ON, D, C. 20%S E e
- DEC 101991 MEMORANDUM FOR: R. F. Fraley, Executive Director Advisory Comittee on Reactor Safeguards FROM: E. L. Jordan, Director Office for Analysis and Evaluation of Operational Data
SUBJECT:
PROPOSED HINOR RULEMAKING TO MODIFY OPERATING POWER REACTOR EVENT REPORTING REQUIREMENTS -- 10 CFR 50.72 AND 50.73 Enclosed is a Negative Consent Paper for the Comission, including a Notice for Proposed Rulemaking and draft Regulatory Analysis, on minor modifications to nuclear power reactor event reporting requirements. We are submitting this package to the Advisory Comittee on Reactor Safeguards (ACRS) for information and determination of whether or not to review the proposed rulemaking. This proposal has been coordinated with RES and NRR.
When approving the rulemaking activities, the ED0's directive to us was to ensure a timely publication of the final rule and to minimize resource expenditures. Due to $he expedited schedule, we respectfully suggest that the ACRS defer its review until after the comera resolution; i.e., the final rulemaking stage. We would appreciate your letting us know the Comittee's decision as soon as practical.
This proposed minor rulemaking would amend 10 CFR 50.72, "Immediate Notification Requirements for Operating Nuclear Power Reactors" and 10 CFR 50.73, " Licensee Event Reporting System." Based on the staff's review and analysis of the reactor operating experience over the past 7 years, the industry coments received during the NRC's Fall 1990 Event Reporting Workthaps, and the staff comments on " Event Reporting Systems 10 CFR 50.72 and 50.73 -- Clarification of NRC Systems and Guidelines for Reporting," NVREG-1022, Revision 1 (Draft), we are )roposing changes to 50.72(b)(2)(ii) and 50.73(a)(2)(iv). Specifically, tie proposed changes involve relaxation of current reporting requirements primarily for invalid actuations of certain engineered safety features (e.g., reactor water cleanup system, control room emergencyventilationsystem). Review of these events over a period of several hundred reactor-years of operation has identified no safety concerns and has provided little useful information upon which to assess plant performance. Relaxing the requirement for a limited set of specifically defined ESF actuations will reduce the industry's reporting burden and the NRC's response burden in event processing, review and assessment so that the resources can be applied to safety-related activities. Deletion of these reporting requirements will have essentially no impact on the NRC's ability to fulfill its mission to ensure public health and safety.
9302030106 930129 PDR PR.
50 57FR28642 PDR
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R. F. Fraley 2-If you have any questions-or wish to discuss this matter further, please contact me or the AE00 staff contacts: Raji Tripathi (X24435) for 10 CFR
-50.73 and Eric Weiss (X29005) for 10 CFR 50.72. ];
i
/5 Edward L. Jordan, Ofrector Office for Analysis and Evaluation of Operational Data
Enclosures:
As stated Distribution: See Page 3
- NRR RES FMiraglia. (via tele) EBeckjord (via tele)'
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\ i 3 Distribution (w/oenclosures): E. Jordan D. Ross T. Novak L. Spessard V. Benaroya P. Baranowsky J. Rosenthal G. Zech T. Hurley, NRR E. Rossi, NRR R. Woodruff, NRR S. Treby, OGC G. Mizuno, 0GC E. Beckjord, RES , W. Morris, RES R. Baer, RES M. Fleishman, RES M. Taylor. OEDO J. Bateman, OEDO T. Martin, RI S. Ebneter, Ril A. Davis, Rlli R. Martin, RIV J. Martin, RV Distribution (w/ enclosures): J. Crooks E. Weiss R. Tripathi M. liarper M. Padovan AE00 R/F DSP R/F TPAB/RF
1t N0dedtlanal t t lon The Commissioners ; [ ton James M. Taylor, Executive Director for Operations lubiecti PROPOSED MINOR RULEMAKING TO MODIFY OPERATING POWER REACTOR ! EVENT REPORTING REQUIREMENTS - 10 CFR 50.72 AND 10 CFR 50.73-
Purpose:
To obtain Commission approval for ?ub11 cation of a federal 4 Reatster notice of proposed rulema cing. . EEh9 tog The staff's reactor operating experience review over the $j past 7 years has shown that some unnecessary reporting , exists. In addition, there is a disparity and diversity among the licensees in understandin exisl.ing event reporting rules and,g the intent of the therefore..in their applications. The NRC Regulatory Impact Study L 1395) indicated a need for clarification intentof of-the(Draft HUR ; the rules and for additional guidance on event-reporting. -
-In the Fall of 1990, in four workshops on event reporting, organized by AE00, NRR and NMSS, the staff interacted with -
licensees and industry-supported organizations to obtain feedback on their experience with event reporting under the-existing rules. Subsequently, a task group (AE00, NRR, OGC,- ADM) was organized to provide clarification of the -intent of 4 Contacts- ,!
-Raji Tripathi, AE00 <l (301)492-4435 j 1:
- Eric Waiss, AE00 't, (301) 02e9005 i' l
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i ( 1 Prodoettfonot i the current rules to improve the uniformity and completeness of operating reactor event reporting, , In September 1991, AE0D issued for camment a draft NVREG-1022, Rev.l. " Event Reporting Systems 10 CfR 50.72 and 50.73 Clarification of NRC Systems and Guidelines For Report-ing," which contains improved guidance for event reporting, compiled by the task group. The staff's continuing examination of the reported events during development of this document indicated that certain types ; engineered safety feature (ESF) actuations,of invalid are not j important to safety, and any resources expended in reporting s t these events could be better spent in other safety related activities. However, the staff could not expand the scope of the guidance document to include modifications to the 1 (1) Actuation -- Actuation of a component of an engineered safety feature (ESF) or reactor protection system (RPS) is defined as either: (a) Receipt of a signal (s) in the plant's protection system sufficient to satisfy the protection channels' coincidence logic necessary to-activate the ESF or the RPS (system or component , independent of whether or not the ESF, or the RPS, or the compon)ent operatost or . (b) deliberate or inadvertent action (s) (manual or automatic condition (s)thatactivatestheESFortheRPS(system /co)mponent),or plant without the protection channal coincidence logic being satisfied (e.g., manual actuation of a safety injection pump, an electrical jumper being used to start an emergency diesel generator, or set-point drift causing a boiling water reactor main steam safety / relief valve to open). (2) Valid ESF or RPS actuations are those that are: (a) automatically initiated by the measurement of an actual physical , system parameter that was within the established set point band of the sensor that provides the signals to the protection system's ' I logic (whether or not the ESF/R?S functions properly or a need exists);or . (b) manually initiated in response to plant conditions. (3) Invalid actuations are other than those that are considered to be
" valid" as defined above. Examples of such events -include those initiated by spurious voltage spikes, inadvertent manual actions.(e.g.,_
bumpingcabinets,misplacedjumpers,actuatingwrongswitches), equipment failures, or radio frequency interference. 2 I . _ .- .
Prededsf0nal existing reporting requirements. Neither was it possible to incorporate this document, by reference, in amending the existing rules. Consequently, we were advised by OGC to keep the two issues separate - let the guidance document : clarify the intent of the existing rules, but-initiate a separate rulemaking activity to modify the current reporting requirements to relax the reporting of selected types of ES: 1 actuations. Discussion: Enclosure 1 contains the proposed rule to make minor modifications to the existing reactor event reporting requirements. The proposed rule will have minimal impact on the NRC's ability to fulfil its safety mission because the : deletion of the specified reporting requirements pose little r or no safety concerns. This reduction would also be consistent with the objectives and the requirements of the- - Paperwork Reduction Act. The following are the points considered in the proposed- . amendments to the existing regulation - In10CFR50.72(b)(2)(ii)and50.73_(a)(2)(iv)..the existing rules require reporting of an event or condition that results in a manual or automatic actuation of an-engineered safety feature (ESF), including the reactor - protectionsystem(RPS),exceptwhentheactuationresulted from or was part of a pre planned sequence during testing or .: reactor operation. Based on reviews that indicated the frequencies of such occurrences at the majority of the plants is low, the staff proposes to make additional relaxations to event reporting as follows:
. The first category excludes those events when an I invalid actuation occurs while-the system is already
_ properly removed from service. -
. The second category excludes events' that involve -
invalid actuations after the safety function had already been completed (e.g. an invalid-actuation of the RPS when all rods were fully inserted, or an invalid containment isolation signal while the-- containment isolation valves were already closed).
. The third category excludes events' involving invalid--
actuation, isolation, or_ re-alignment of a limited-set of ESF systems, subsystems, or components (1 e., when an invalid- actuation, isolation, or re-alignment of L only the- RWCU system,- or any of the following four - ventilation systems: CREV system, reactor butiding -+ ventilation system, fuel building ventilation: system, auxiliary building ventilation system,_or their equivalent ventilation systems occurs)._ . 3 a
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. The fourth category excludes events that involve actuations of ESF components (which have both protective (ESF) and non protective (non ESF) actuation circuitry] when the actuation results from a signal originating in the non ESF circuitry. For instance, in a boiling water reactor, if an RWCU system isolation occurs because of a high pressure signal, the incident is reportable because the signal originated from the protective (ESF) circuitry.
However, if the RWCU isolation occurs because of a non-ESF high temperature signal, the event is not ! reportable because the signal originated in the non-ESF circuitry. Although the same system components respond in both instances, in the latter case the triggering mechanism was intended only to protect the RWCU system resins from damage. However, unplanned reactor shutdowns originating from any source (i.e., , from the RPS as well as other anticipatory or non-RPS i signals) continue to be reportable. The intent of the rule changa, however, is that any invalid actuations of other ESFs (such as emergency core cooling system isolations/actuations; containment isolation valve closures that affect cooling systems, main steam flow, i essential support systems, etc.; containment spray { actuation; and, residual heat removal system isolations), not excluded above, will still continue to be reportable. I' Furthermore, licensees will also continue to submit LERs if a deficiency or condition assnciated with any of the invalid ESF actuations of the RWCU or the CREV systems (or other equivalent ventilation systems) satisfies any reportability 3 criteria under 50.72 and 50.73. Resour:es: We estimate the resource commitment of 1.0 staff-year for ; AEOD and 0.5 staff-year for other NRC offices to prepare, review and approve the rule changes. The proposed rule changes are expected to result in about a 5-10 percent re-duction in the number of LERs, i.e., about 150 LERs each year. Similar savings are estimated in the 50.72 notifica-tions. The incremental cost reduction to industry is about $2600 per event for both 50.72 and 50.73 reports. For the NRC, the reduction in processing cost from a 5 to 10 percent reduction in 50.72 notifications would be negligible, be-cause the entire duty officer staff would remain the same, and the screening of these relatively unimportant events by NRR would not affect total event screening effort signifi-cantly. There would, however, be cost savings for NRC due to a reduction in LER screening, coding and processing. The incremental cost reduction to the NRC in LER screening and 4 i
( l PredeeltJonal processing is estimated to be about $2400 per LER. Recommen.d.g11cn Unless the staff is instructed to the contrary within 10 days from the date of this paper, the enclosed amendments to 10 CFR 50.72 and 50.73 will be issued as a proposed rule. (sordination: The Office of General Counsel has no legal objection. James M. Taylor, Executive Director for Operations Encisoures:
- 1. Federal Regliin Notice
- 2. Draf t Regulatory Analysis Distribution:
Commissioners j-OGC OCA DIG REGIONAL OFFICES EDO SECY i. 1 5
i \ t ENCLOSURE i I Pwdocido;;zo IAE12-11 HUCLEAR REGULATORY COMMISSION 10 CFR PART 50 ; f RIN 3150 AE12 Minor Modifications to the Nuclear Power Reactor Event Reporting Requirements AGENCY: Nuc1 car Regulatory Commission. ACTION: Proposed rule.
SUMMARY
- The Nuclear Regulatory Commission (NRC) proposes to amend its regulations to make minor modifications to the current nuclear power reactor event reporting requirements. The proposed changes would apply to all nuclear power reactor licensees, and delete reporting requirements for some events that have been determined to be of little or no safety significance. This rule change '
will reduce the industry's reporting burden and the NRC's response burden in event review and assessment. The proposed rule changes will have minimal impact on the NRC's ability to ensure public health and safety. DATES: T' omment period expires 75 days following publication in the federal Register. Comments received after this date will be considered if it is practical to do so, but the NRC is able to assure consideration only for comments received on or before this date. 1
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Pled 0cisint fAE12-11 ADDRESSES: Mail written coments to: U.S. Nuclear Regulatory Commission, Washington, DC 20555, ATTN: Docketing and Service Branch. Deliver comments to One White Flint North,11555 Rockville Pike, Rockville, MD, between 7:30 am and 4:15 pm on federal workdays. Commenters are encouraged to submit, in addition to the original paper copy, a copy of their comments in an electronic format on IBM PC DOS-compatible 3.5- or 5.25 inch, double-sided, diskettes. Data files should be provided in Wordperfect 5.0, or 5.1. ASCII code is also acceptable, or if formatted text is required, data files should be submitted in IBM Revisable Format Text Document ContentArchitecture(RFT/DCA) format. Copies of the environmental assessment, the draft regulatory analysis and the finding of no significant impact, and the supporting statement submitted to OMB, and comments received may be examined at: The NRC Public Document Room, 2120 L Street NW. (Lower Level), Washington DC. FOR FURTHER INFORMATION CONTACT: Raji Tripathi (10 CFR 50.73) or Eric Weiss (10 CFR 50.72), Office for Analysis and Evaluation of Operational Data U.S. Nuclear Regulatory Commission, Washington DC 20555, Telephone (301) 492-4435 'and 492-9005, respectively. 2 I l:t . . __ _ _ - _- _
4 i Prod % ' fAE12 SUPPLEMENTARY INFORMATION: BACKGROUND l l The Commission is proposing minor changes to the current nuclear power j reactor event reporting requirements contained in 10 CFR 50.72, " Immediate Notification Requirements for Operating Nuclear Power Reactors," and 10 CFR 50.73, " Licensee Event Reporting System," as part of on going activities-to- ! e improve its regulations. ; In this regard, various reviews by the NRC staff of operating experience-and the patterns of licensees' reporting of operating events since 1984 have ;- indicated that the reporting of certain types of events are not contributing;to !' the operating base and is no longer necessary. Such unnecessary reporting is f consuming both resources in preparation and review that would be better applied elsewhere. Over the past several years, the NRC staff has increased its attention to j event reporting issues to ensure uniformity, consist'ency and completeness in event reporting. As a result, in September 1991, AE00 issued for comment a draft NUREG-1022, Revision 1,3 " Event Reporting Systems 10 CFR 50.72 'and 50.73 -- Clarification of NRC Systems and Guidelines' for Reporting," which contained improved guidance for event reporting, compiled by the Task Group. The'NRC t .I A free single copy may be. requested by writing to the Distribution and Mail-Services Section, U.S. Nuclear Regulatory Commission, Washington DC 20555' . A copy is also available for inspection or copying for a fee at the NRC Public Document Room, 2120 L Street, NW (Lower level),. Washington, DC, l~ \ 3
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[ ON IAE12-11 staff's continuing examination of the reported events during development of this document indicated that certain types of invalid engineered safety feature (ESF) actuations' are not important to safety, and any resources expended in reporting these events could be better spent in other safety-related activities. In i addition, the staff determined that for the same reasons ESF equipment actuations need no longer be reported if the actuations cccurred from non ESF signals. Based on the NRC's' evaluation of both the reported events since January 2 (1) Actuation -- Actuation of a component of an engineered safety feature (ESF) or reactor protection system (RPS) is defined as either: (a) in the plant's protection system sufficient Receipt to satisfyof a protect the signal (s) ion channels' coincidence logic necessary to activate the ESF or the RPS (system or compor nt , independent of whether or not the ESF, or the RPS, or the compon)ent operates; or (b) deliberate or inadvertent action (s) (manual or automatic) or plant condition (s) that activate the ESF or the RPS (system / component), without the protection channel coincidence logic being satisfied (e.g., manual actuation of a safety injection pump, an electrical jumper being used to start an emergency diesel generator, or set-point drift causing a boiling water reactor main steam safety / relief valve to open). ' (2) Valid ESF or RPS actuations are those that are: (a) automatically initiated by the measurement of an actual physical system parameter that was within the established set point band of the sensor that provides the signals to the protection system's logic (whether or not the ESF/RPS functions properly or a need exists); or . (b) manually initiated in response to plant conditions. (3) Invalid actuations are other than those that are considered to be-
" valid" as defined above. Examples of such events include those initiated by spurious voltage spikes, inadvertent manual actions (e.g.,
bumpingcabinets,misplacedjumpers,actuatingwrongswitches), , equipment failures, or radio frequency interference. l 4 i i l
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L 6 [ Pr % ; fAE12-11 1984, when the existing rules first became effective, and the comments received
- during the Event Reporting Workshops, some needed improvements in the rules were identified. For instance, it was determined that some events only involving invalid ESF actuations are of little or no safety significance but are currently reportable pursuant to 10 CFR 50.72 (b)(2)(ii) and 50.73 (a)(2)(iv). Events in this category are invalid actuations of, for instance, the reactor water clean up (RWCU) system and the control room emergency ventilation (CREV) system, which actuate various system components, but pose no safety concerns.
The original Statements of Consideration for the current event reporting _ regulations, 10 CFR 50.72 and 50.73, indicated that ESF systems, including the reactor protection system (RPS), are provided to mitigate the consequences of a significant event. Therefore, ESFs should (1) work properly when called upon and (2) should not be challenged frequently or unnecessarily. Those Statements of , Consideration also indicated that operation of an ESF as part of.a pre planned operational procedure or test need not be reported. The Commission also noted that ESF actuations, including reactor trips, are frequently associated with , significant plant transients and are indicative of events .that' are of safety significance. At that time, the Commission also required all ESF actuations,- including the.RPS actuations, except as noted,_--' manual or automatic, valid or-invalid -- to be reported to the NRC by telephone within 4 hours of occurrence- , followed by a written Licensee Event Report (LER) within 30 days of the incident. The reported information is-used by the NRC in confirmation of the licensing bases,-identification of precursors to severe core damage, reviews of management
-control systems, performance indication, and the identification of- actions toL 5
a-. ,- . -
t I hedoclsim l IAE1211 > minimize unnecessary actuations of safety systems. However, after a review of several hundred reactor years of reactor opera-tional experience, the NRC staff has determined that a certain set of invalid ESF actuations have not provided safety significant information necessary for the NRC to be abic to meet its mission to ensure public health and safety, and any re-sources expended in reporting such events could be better spent on other safety-related activities. Relaxina reporting requirements on certain ESF actuations, primarily invalid actuations, could save both the industry and the NPI resources. The ! Commission emphasizes that not all invalid ESF actuations are being relaxed from reporting. The relaxations in event reporting requirements as contained in the proposed rule apply only to a limited set of specifically defined invalid ESF actuations. Such events, for example, include invalid actuation, isolation, or re alignment of a limited set of ESF systems, subsystems, or components (i.e., _ i when an invalid actuation, isolation, or re-alignment of only the RWCU system, l or any of the following four ventilation systems: CREV system, reactor building ventilation system, fuel building ventilation system, auxiliary building ventilation system, or their equivalent ventilation systems occurs). Such ac t u a t i on/ i s ol a t i o n/re - al i g nme n t events are of minimal safety significance because they result in the system being in the safe condition, and contribute little to operating experience data. However, invalid actuations of other ESFs such as emergency core cooling system isolations/actuations; containment i isolation valve closures that affect cooling systems, main steam flow, essential 6
4 ( J PredocMond v support systems, etc.; containment spray actuation; and, residual heat removal system isolations will still be reportable, in the proposed rule, in addition : to the specified invalid ESF actuations, other ESF actuations are being excluded. The Commission, however, considers it prudent to emphasize that if an invalid ESF actuation reveals a defect in the system such that it failed or would fail to perform its intended function, the event is reportable under other requirements of 10 CFR 50.72 and 50.73. To be specific, invalid ESF actuations which reveal a condition or a deficiency that may have actual or potential safety . significance, such as an adverse impact on safety-related equipment and conse- l quently on the ability to shut down the reactor and maintain it in a safe shutdown condition, or a significant radiological release or potential exposure to plant personnel or the general public, or a compromise of control room habitability, continues to be reportable. Invalid ESF actuations that are excluded by this rule change, but occur as a part of a reportable event, should continue to be described as part of the j. reportable event. Nothing here should be interpreted as precluding a complete. l accurate and thorough description of an event when it is reportable under these or any other reporting requirements-of 10 CFR 50.72 or 50.73. I The NRC is proposing to relax only the event reporting requirements. Any anomalies that are excluded from reporting would need continued licensee attention under 10 CFR 50, Appendix B, " Quality Assurance Criteria- for Nuclear Power Plants and Fuel ' Reprocessing Plants." For example, based en the NRC's review of reactor operating' experience, the potential exists for increased 7
- i. J Prodocis!0nal IAD Z-1.1 occupational radiation exposures associated with the licensees' event investigation and recovery of the RWCU system following invalid isolations.
Tbn ~re, r licensees must continue to take steps necessary to minimize undue sW + or.s of the RWCU system and to reduce the potential for unnecessary ccet.pational exposures. Also, invalid CREV isolations continue to need to be mininiized so that the control room operators are not distracted from attending to events of greater urgency. Description Relaxing the requirement for reporting of ESF actuations that are of little or ne safety significance will reduce the industry's reporting burden and the NRC's response burden. As noted earlier, the proposed rule will have minimal impact on the NRC's ability to fulfil its safety mission because the deletion of certain reporting requirements pose little or no safety concerns. This reduction would also be consistent with the objectives and the requirements of the Paperwork Reduction Act. The f711owing are the points considered in the proposed amendments to the regulation:
- 1. 10 CFR 50.72 and 50.73 In 10 CFR 50.71 (b)(2)(ii) and 50.73 (a)(2)(iv),
the existing rule requires reporting of an event or condition that results in a manual or automatic actuation of an ESF, including the RPS, except when the actuation resulted from or was part ,f the pre-planned sequence during testing or reactor operation. The NRC proposes to make additional relaxations to event reporting as follows: 8 P
( a a Predecisional IAR2.:11-
. The first category excludes those events when an invalid ESF or RPS actua-tion occurs when the system is already properly removed from service.
. The second category excludes events that involve invalid- ESF or RPS .,,
actuations after the safety function had already been .e.eted (e.g., an -- invalid actuation of the RPS when all rods are fully inserted, or an- i invalid containment isolation signal while the containment isolation . valvec were already closed).
. The third category excludes events involving invalid actuation, isolation, or re-alignment of a limited set of ESF systems, subsystems, or components (i.e., when an invalid actuation, isolation, or re-alignment of only the RWCU system, or any of the following four ventilation systems: CREV system, reactor building ventilation system, fuel building ventilation sys". m. a miliary building ventilation system, or their equivalent veni.i:? i t t. systems occurs).
The fourth category excludes events that involve actuations of ESF compo-nents [which have both protective (ESF) and non-protective (non-ESF) actuation circuitry] when the actuation results from a signal originating-in the non-ESF circuitry. For instance, in a boiling water reactor, if an RWCU system isolation occurs because of a high pressure signal, the incident is reportable because the signal originated from the protective (ESF) circuitry. However, if the RWCU isolation occurs because of a non-ESF high temperature signal, the event is not reportable because the 9
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Predodtjonal IAE12-Il signal originated in the non-ESF circuitry. Although the same system components respond in both instances, in the latter case the triggering mechanism was intended only to protect the RWCU system resins from damage. However, the Commission remains interested in unplanned reactor shutdowns originating from any source (i.e., from the RPS as well as other anticipatory or non RPS signals) as these events involve transients. Such . events continue to be reportable. The intent of the rule change, however, is that any invalid actuations of i i other ESFs (such as emergency core cooling system isolations/actuations; containment isolation valve closures that affect cooling systems, main steam flow, essential support systems, etc.; containment spray actuation; and, residual heat removal system isolations), not excluded above, will still continue to be reportable. Furthermore, licensees are still required to submit LERs if a ; L deficiency or condition associated with any of the invalid ESF actuations of the RWCU or the CREV systems (or other equivalent ventilation systems) satisfies any reportability criteria under 50.72 and 50.73. Impact Relaxing the current requirement for reporting invalid ESF actuations will reduce the industry's' reporting burden and the NRC's response burden. This reduction would be consistent with the objectives and the requirements of the l l Paperwork Reduction Act. The proposed rule changes will have minimal impact.on ! the NRC's ability to fulfil its mission to ensure public health and safety f l 10 t
L t s o-Prodocisional IAE12-11 because the reporting requirements that the NRC proposes to delete have little or no safety significance. It is estimated that the proposed changes to the existing rules will result in about 150 (or 5-10 percent) fewer Licensee Event Reports each year. Similar reductions are expected in the number of prompt event notifications reportable under 10 CFR 50.72. The licensees are encouraged to submit their estimates on impact of the proposed rule change as comments. Finding of No Significant Environmental Impect: Availability The Commission has determined under the National Environmental Policy Act of 1969, as amended, and the Commission's regulations in Subpart A of 10 CFR Part 51, that this rule change, if adopted, would not be a major Federal action significantly affecting the quality of the human environment and, therefore, an environmental impact statement is not required. The proposed rule relaxes current reporting requirements 'for certain invalid engineered safety feature actuations which, based on the NRC staff's review of several hundred reactor-years of operational experience have been determined to be of little or no safety significance. The environmental assessment and finding of no impact on which this determination is based are available for inspection at the NRC Public Document Room, 2120 L Street NW. (Lower Level), Washington DC. Single copies of the environmental assessment and finding of no signitf cant impact, and the 11 I'
r Prodggof IAE12-Il regulatory analysis are available from: Raji Tripathi, Office for Analysis and i Evaluation of Operational Data, U.S. Nuclear regulatory Commission, Washington, DC 20555, telephone: (301) 492-4435. Paperwork Reduction Act Statement This proposed rule amends information collection requirements that are' l subject to the Paperwork Reduction Act of 1980 (a4 U.S.C. 3501 et seq.). This j rule has been submitted to the Office of Management and Budget for review and approval of the Paperwork requirements. Relaxing the current requirement for reporting invalid ESF actuations will reduce the industry's reporting burden and the NRC's response burden. This i' reduction would be consistent with the objectives and the requirements of the i Paperwork Reduction Act. The proposed rule changes will have minimal impact on the NRC's ability to fulfil its mission to ensure public health and safety because the reporting requirements that the NRC proposes to delete pose little l or no safety concerns. It is estimated that the proposed changes to the existing rules will result in about.150 (or 5-10 percent) fewer Licensee Event Reports ;, each year. Similar reductions are expected in the number of prompt event notifications reportable under 10 CFR 50.72. Send comments regarding this burden estimate or any other aspect of this-collection of information, including suggestions for reducing this burden, to the ;! i; Information and Records Branch, U.S. Nuclear Regulatory Commission,, Washington j; 12 l' a
},y .
PredecisI0ng IAE12-Il DC 20555; and to the Paperwork Reduction Project-(3150--) 0ffice of Management: and Budget, Washington DC 20503. L t Regulatory Analysis .
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The Commission has prepared a draft regulatory analysis on!this proposed-rule change.- The analysis examines the costs and benefits of-the alternatives-considered by the Commission. The draft analysis is available for inspection in.. the NRC Public Document Room, 2120 L Street NW. (Lower Level), Washington DC. Single copies of the draft analysis may.be obtained from: Raji Tripathi, Office for Analysis and Evaluation of Operational Data, U.S. Nuclear Regulatory._ Commission, Washington DC 20555,-Telephone (301) 492-4435. Regulatory Flexibility Certification. 1 In accordance with the Regulatory Flexibility-Act of 1980, -(5 U.S.C. ~ 605' - (B)), the Commission certifies that this rule will .not, if promulgated, have 'a-- significant ; economic impact on a substantial- number of'small-- entities.- . The - , proposed rule affects only the licensing.and cpert. tion of nuclear power plants. The ~ companies that own these _ plants: do not fall within the scope -ofsthe-definition of "small entities" set forth in the_ Regulatory Flexibility Act or thel Small Business Size Standards set out in regulations issued by the Small Business;
-j Administration Act in 13 CFR Part 121. T 13
Predecisional IAfl2-Il Backfit Analysis As required by 10 CFR 50.109, the Commission has completed an assessment of the need for backfit analysis for the proposed rules. The proposed amendments include relaxations of certain existing requirements on reporting of information to the NRC. These changes neither impose additional reporting requirements nor require modifications to the facilities or their licenses. Accordingly, the NRC has concluded that the proposed rules do not constitute backfit and, thus, a backfit analysis is not required. List of Subjects in 10 CFR Part 50 Antitrust, Classified information, Criminal penalty, Fire prevention, Incorporation by reference, Intergovernmental relations, Nuclear power plants and reactors, Penalty, Radiation protection, Reactor siting criteria, Reporting and record-keeping. For the reasons set out in the preamble and under the authority of the Atomic Energy Act of 1964, as amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC is proposing to adopt the following amendments j to 10 CFR Part 50. i-l l 14 l l
r , Prodocis!0nal IAE12-Il PART 50 DOMESTIC LICENSlHG OF PRODUCTION AND UTILIZATION FACILITIES
- 1. AUTHORITY: Sections 102,103,104,105,161,182,183,186,189, 68 Stat.
936, 937, 938, 948, 953, 954, 955, 956, as amended, sec. 234, 83 Stat. 1244, as amended (42 U.S.C. 2132, 2133, 2134, 2135, 2201, 2232, 2233, 2236, 2239, 2282); secs. 201, as amended, 202, 206, 88 Stat. 1242, as amended, 1244, 1246 (42 U.S. C. 5841, 5842, 5846). Section 50.7 also issued under Pub. L. 95-601, sec.10, 92 Stat. 2951 (42 U.S.C.5851). Section 50.10 also issued under secs. 101,185, 68 Stat. 936, 955, as amended (42 U.S.C. 2131, 2235); sec. 102, Pub. L. 91-190, 83 Stat. 853 (42 U.S.C.4332). Sections 50.13, and 50.54(dd), and 50.103 also issued under sec. 108, 68 Stat. 939, as amended (42 U.S.C. 2138). Sections 50.23, 50.35, 50.55, and 50.56 also issued under sec.185, 68 Stat. 955 (42 U.S.C. 2235). Sections 50.33a, 50.55a and Appendix Q also issued under sec.102, Pub. L. 91-190, 83 Stat. 853 (42 U.S. C 4332). Sections 50.34 and 50.54 also issued under sec. 204, 88 Stat. 1245 (42 U.S. C. 5844). Sections 50.58, 50.91, and 50.92 also issued under Pub. L. 97-415,96 Stat.2073(42U.S.C.2239). Section 50.78 also issued under se. 122, 68 Stat 939 (42 U.S.C. 2152). Sections 50.80 - 50.81 also issued under sec.184, 68 Stat. 954, as amended (42 U.S.C. 2234). Appendix-F also issued under sec.187, 68 Stat. 955 (42 U.S.C. 2237). For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273); Section; 50.5, 50.46(a) and (b), and 50.54(c) are issued under sec.161b, 68 - Stat. 948, as amended (42 U.S.C. 2201(b)); Sections 50.5,50.7(a),50.10(a)-(c), 50.34(a)and(e),50.44(a)-(c),50.46(a)and(b),50.47(b),50.48(a),(c),(d), and(e),50.49(a),50.54(a),(i),(1)(1),(1)-(n),(p),(q),(t),(v),and(y), 15 i
j s .< t ; Prodocis10nal JfE12-Il 50.55(f), 50.55a(a), (c)-(e), (g),.and (h), 50.59(c), 50.00(a), 50.62(b), 50.64(b), 50.65, and 50.80(a) and (b) are issued under sec. 1511, 68 Stat. 949, asamended(42U.S.C.2201(i));andSections50.49(d),(h),and(j),50.54(w), I-(z), (bb), (cc), and (dd), 50.55(e), 50.59a(b), 50.61(b), 50.62(b), 50.70(a), 50.71(a)-(c) and (e), 50.72(a), 50.73(b), 50.61(b), 50.62(b), 50.70(a), 50.71(a)- (c) and (e), 50.72(a), 50.73(a) and (b), 50.74, 50.78, and 50.90 are issued under sec. 1610, 69 Stat. 950, as amended (42 U.S.C. 2201(o)).
- 2. In 10 CFR 50.72, paragraph (b)(2)(ii) is revised to read as follows:
"Any event or condition that results in a manual or automatic actuation of an engineered safety feature (ESF), including the reactor protection system (RPS),
except when: (A) the actuation results from or is part of a pre-planned sequence during testing or reactor operation; or (B) an invalid actuation occurs: r (1) when the system is properly removed from service, or [ (2) after the safety function has been already completed, or . i , 16 l i i
s .r - g Predecisig IAE12-11
-(3) -that'_ involves actuation, isolation, or re alignment of only the reactor water clean up system, .or any of the following_ four ventilation systems: control room emergency- ventilation - system, reactor building ventilation system, fuel building ventilation system, -and auxiliary building ventilation system, or their equivalent ventilation systems; or (C) the actuation involves ESF (except the RPS) components and'results from a signal that originated from non-ESF (e.g., control) circuitry."
- 3. In 10 CFR 50.73, paragraph (a)(2)(iv) is revised to read as follows:-
"Any event or condition that results in a manual or automatic actuation of an engineered safety feature (ESF), including the reactor protection system (RPS),
except when: (A) the actuation resulted from or was part of a pre-planned sequence during testing or reactor operation; or i (B) an invalid actuation occurred and l l-(1) the system was properly removed from service, or l-17 1
r..,, ; l fAE12-ll (2) the safety function was already completed, or (3) involved actuation, isolation, or re-alignment of only the reactor i water clean-up system, or any of the following four ventilation systems: control room emergency ventilation system, reactor building ventilation system, fuel building ventilation system,. and auxiliary building ventilation system, or their equivalent ventilation systems; or (C) the actuation involved ESF (except the RPS) components and resulted from a signal that originated from non-ESF (e.g., control) circuitry." Dated at Rockville, MD, this day of , 1991. I James M. Taylor, Executive Director for Operations
. j:
i i i 18
ENCLOSURE 2 1 H t, Regulatory Analysis tk The NRC staff has prepared a draft regulatory analysis of this proposed rule change. The analysis examines the costs and benefits of the alternatives considered by'the NRC. The following is the draft analysis:
- 1. Statement of the Problem The Nuc3 car Regulatory Commission (NRC) is proposing to amend its regulations on reporting of operating reactor events.
Specifically, the affected regulations are 10 CFR 50.72, i:
"Immediate Notification Requirements for Operating Nuclear Power Reactors", and 10 CFR 50.73, " Licensee Event Report System". i Currently, 10 CFR 50.72 and 50.73 require that NRC licensees for nuclear power reactors report any event or condition that involves actuation of any engineered safety feature (ESF),
including the reactor protection system (RPS), except for actuations that resulted from and were part ofEa preplanned sequence during testing or during reactor operation. The events are required to be reported via a telephone within 4 hours of discovery pursuant to 10 CFR 50.72(b) (2) (ii) and within 30 days in a Licensee Event Report (LER) in accordance with 10 CFR 50.73 (a) (2) (iv) . Approximately 40 percent of the LERs _ (over 800) received annually involve ESF actuations; a similar number of telephonic event notifications are also made. Based or. the review of reactor operational experience since January 1, 1984, when the current 10 CFR 50.72 and 50.73 first became effective, the NRC staff has determined that the reporting of certain events of little or no safety significance constitutes a large number of reports. Examples of events in this category include invalid actuations of certain ESFs, such as isolations of the reactor water cleanup system, actuations of the control room emergency ventilation system, and invalid RPS actuations when the reactor is already shutdown. The staff has concluded that reports on these events are not necessary for the NRC to perform its safety mission. Therefore, the staff proposes to relax reporting of certain events of lictle or no safety significance, deferring to licensee oversight. The proposed rulemaking action is consistent with and responsiee II to NRC findings from the Regulatory Impact Survey, NUREG-1395,
" Industry Perceptions of the Impact of the U. S. Nuclear
- Regulatory Commission on Nuclear Power Plant Activities",_ Draft Report, March 1990.
- 2. Qbiectives ,
The present reporting requirements of 10 CFR 50.72 and 50.73 l require reporting of all ESF actuations, including the RPS L system, except for actuations that resulted from and were part of a preplanned sequence during testing or during reactor oparation.
Ti( DRAFT The proposed changes will eliminate the reporting. requirements on certain types'of-events that are now reportable and have been determined to be of;little or no safety significance. Thisi relaxation will not hamperLthe NRC's ability to meet.its mission-to protect public health and safety.'
- 3. Alternatives 6 No other reasonable alternatives were identified. -The only alternative to the proposed action is for the NRC to take no action at.this time.
- 4. Consecuences
- a. Costs and Danefits of Alternatives The only reasonable alternative.to the proposed action identified- l 1s to take no action, the incremental costs and benefits of that alternative ara zero. IIowever, taking no action would result in continued reporting of events that are not needed for the NRC l staff to fulfil its safety mission, and consequently unnecessarily consume.both NRC and industry resources.
4 The principal benefit of the-proposed amendments is a reduction in the efforts-expended by both the NRC and the licensees on
-issues of little or no safety significance. This will free.both NRC and licensee resources that could be better spent on issues of gtcater importance.. Based on review of past.LER-data, the; proposed rule changes are expected to-result in about 150 (orf5
.to 10 percent of-the total) fewer LERs. The same reduction is-expected in the number of immediate event notifications.
. The cent of the proposed action consists of the cost of the rulemaking effort by NRC, and the potential costs of rewriting. procedures and personnel-training provided to the.their. staffs by- , the licensees. Cost savings for both the NRC and.the industry are shown in Table-1 below. .HRC costs were calculated in accordance with the guidance in NUREG/CR-3568, "A Handbook for-Value-Impact Assessment," and general cost-benefit methodology.- 1 It was assumed that industry expends 50 staff-hours for eachtof. these relatively simple LERs,. and- about 4 hours for each 50.72 'l notification. At.$48-per hour, the incremental-cost to industry: is therefore about $2600 for both' reports. For NRC, the processing cost reduction due to a 5 to 10 percent reduction-in a 50.72 notifications would be negligible,-because the entire duty , officer system would remain the.same, and the' screening of these- 1 relatively' unimportant events by NRR would not affect total-event 1 screening effort significantly. 'There would, however, be cost savings.for NRC due to a reduction in LER processing, review and assessment. Assuming that NRC expends 50= staff-hours for evaluating each LER,-at $48 per hour,-the incremental cost to the NRC is.therefore about $2400 per LER. ,
1
' .-t --
-(;d DRAFT . Table 1. Estimated Incremental Impact Based-on an Estimated Annual Reduction'ofE150 Licensee Event Reports 99sig- Annual 30-Year Present- Total Costs Worth-Factor. Costs Over Based on a 5% Real 30 Years Discount Rate Industry Cost $390,000 15.4 $6,000,000 ($2600 per report) NRC Cost ($2400 per $360,000 -15.4 $5,500,000 report) The proposed rulemaking could save both the NRC and industry overi
$350,000 a year, or over $5,500,000 each over-the next 30 years (present worth; 5 percent discount rate). The cost of the !
rulemaking itself would require about 1.5 NRC staff-years, reducing the cost savings by about $150,000 the first year. 1[n addition, the cost savings for NRC may be somewhat less, because-the types of LERs to be eliminated are ones for which review and assessment would be less than that for the average-LER. Assuming the cost-of_ rewriting procedures is about $3300_per licensee, the result would be to subtract about.$260,000-from the1 ' industry cost-savings the first year. The cost of personnel training provided to their staff by the-licensees is more difficult.to determine. Since the rulemaking will decrease- !: reporting requirements, it is hoped that training would be { minimal and cost less than the first year's savings. !: i NOTE:(******** Estimates of-reduction in the licensee burden will
.lua solicited through the Federal Register. ,
Notice.******************) i
- b. Impacts on Other Requirements Because the LERs and immediate notifications to be eliminated are of little or no safety significance, the action will not have-any impacts on'other'NRC programs or requirements, licensee operations or other activities..
- c. Constraints There are no known constraints (legal, institutional, scheduling,- o
. enforceability, or policy) on the. industry or on the NRC for-the proposed action.
- 5. Decision Rationale The proposed changes will eliminate some existing reporting requirements. There should be-a reduction of approximately 150 i:
I.
+
_49 DRAFTL l telephonic event: notifications and'LERs-per year (aboutK51to 10 percentiof the1 yearly-total), duetto the elimination of-reporting; ofJcertain1ESF-actuations.- The' extent of the; changes will vary. from1 licensee to licensee. We: expect that-the totalinumberiof~
- reports and: the associated information- that _ needs to i be prepared by the' licensees, and. subsequently reviewed by the NRC,-;will~
decrease moderately.
- 6. Implementation
- a. Schedule for Implementing the Proposed Requirement The final rule is expected to be published approximately nine-months after publication of_the proposed: rule, or about February-
=1993. The new rule would become effective one month later.-
Regulatory guidance will be provided_by the latest revision of'
~NUREG-1022, " Event Reporting Systems, 10 CFR 50.72'and 50.7 , p ClarificationofNRCSystemsandGuidelines-forReporting".p~ =
U This NUREG will be revised to reflect completion of the - rulemaking action proposed above, and the revised NUREG- -
!i publication will be synchronized with the final rulemaking- 1 changes to 10 CFR 50.72 and 50.73.
- b. Relationship to Other Existing or. Proposed Requirements-No effect on other NRC requirements is--anticipated. .The- _ _
rulemaking:will be coordinated with the issuance of'a! revision of: NUREG-1022, as discussed above. The rulemaking and guidance; revision are complementary. The NRC staff requests public commentr, on the-draft analysis which may be submitted to the NRC as indicated.under the , ADDRESSES heading.
' Copies of-the latest revision of NUREG-1022 may be.
~
purchased from the Superintendent of Documents, U.S. Government Printing Office, P.O. Box _37082, Washington, D.C. 20013-7082. Copies'are also available from the National' Technical'Information
> Service,.5285 Port Royal Road,' Springfield, VA;22161. Ascopy-'is
-also available for inspection or copying for a'Lfee at-the NRC:
Public Decument - Room, 2120 L Street, NW. (Lower Level), Washington, DC. 5
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- December' 13 ~,- 1991 g m//s <
_ MEMORANDUM FOR: . Guy A. Arlotto, NMSS Frank J. Mirag1_.ia, Jr. NRR. Janice E. Moore.:0GC Leonard J. Callan,. RIV Brian W. Sheron. RES-FROM: Edward L. Jordan, Chairman Committee to Review Generic Requirements
SUBJECT:
CRGR MEETING NO. 213 The Committee to Review Generic Pequirements (CRGR) will meet in the morning. on Thursday, December 19, 1991, in-Room'1F-22, OWFN. The' agenda is as follows:
.B:00-8:30 a.m. . - The Committee will discuss further possible CRGR recom-mendations relating to a proposed Supplement to Generic Letter 89-10. reviewed at Meeting No._ 212, 8:30-9: 30 a.m.
W.-Minners (RES) will present for CRGR review the proposed: < Revision 3 to Reg. Guide 1.101, " Emergency' Planning andi 1 Preparedness for Nuclear-Reactors;" LThe' review package isi Item 55, distributed to CRGR members on December 6, 1991; 9:30-10:30 a.m. C.E. Rossi-(NRR) will present for CRGR reviewithe proposed ' Supplement I to Generic- Letter 90-02,. " Alternative Require-ments for Fuel Assemblies in the Design
- Features Section1 of-Technical Specifications."' TheLreview package is'
~ Item'56, distributed to members.onl December._12, 1991.-
10:30-11:30 a.m. The: Committee will discuss' a proposed . amendment to: 10 CFR Parts 72:and 73,-involving proposedirelaxations! i to current reporting requirements primarily.for" invalid actuations of certain engineered safety features. The review package is Item ~57, distributed to CRGR-members on December.12, 1991. If-a CRGR member cannot attend the meeting, it is his res that:an. alternate, who is approved by the CRGR Chairman,:ponsibility to' assure attends the meeting.: Persons making presentations to the CRGR are responsible for (1)' assuring-that : the information required for CRGR review is provided to the Committee;(CRGR 1 Charter IV.B),:(2) coordinating and presenting views;of other offices : (3) as. appropriate, assuring t tat other offices' are-represented during the
-presentation, and (4)' assuring that agenda modifications.are coordinated with' the CRGR: contact (J. Conran X29855) and others involved with the presentation.
Division agenda. items Directors or higher under their purview,management should' attend meetings addressing y plyQf$f~~ ~
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..g. g In accordance:with the E00's-March 29,-1984 memorandum to the Commission con ' '1l ' cerning:" Forwarding of CRGR. Documents- to the' Public Document Room-(PDR),'!- the
__ review packages'for items; scheduled at this meeting', which contain predecis-- ionaliinformation, will- not be released:to the PDR until the-NRC has' consider-ed (in a public forum);or decided the matter addressed by the,information. . OdelnalS%f*d$$ Ed M k. rdan -_Chairmani . . Committee'to Review Generic Requirements . cc: SECY J.---Taylor, EDO Commission (5) J. Lieberman Regional Administrators
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-R. Fraley P. Norry. '
W. Minners
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