ML20213E785
| ML20213E785 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/1984 |
| From: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20213E720 | List: |
| References | |
| FOIA-86-729, RTR-NUREG-1022 NUDOCS 8404300080 | |
| Download: ML20213E785 (5) | |
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\...../.. APR 19 1984 MEMORANDUM FOR: C. J. Paperiello, Chief Emergency Preparedness and Radiological Safety Branch, Region III FROM: Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
SUBJECT:
INTERPRETATION OF PARAGRAPH 50.72(b)(1)(v) of 10 CFR PART 50 (F03007984)
This responds to your memorandum to F. Pagano on this subject dated March 30, 1984. -
., In general, we believe that the interim answers that you propose are overly prescriptive. We had intended that the licensee be given a significant degree of flexibility in interpreting the reporting requirement of 10 CFR 50.72(b)(1)(v) because the details of an event have a considerable bearing on the safety significance of the event. By relying on the licensee's judgment, we hope to encourage free and open communications between the licensee and the NRC regarding matters of safety. By allowing the licensee to use judgment, we hope to avoid trivial or insignificant notifications that would result from overly prescriptive interpretations of the rule.
To some degree, the questions that you raise have already been addressed in
- Supplement 1 to NUREG-1022. I have. enclosed pages 33-35 of that document for your information.
The answer to question 1 in your memorandum is partially covered by answer 4.2 of Supplement 1 to NUREG-1022. Beyond the answer 4.2, I would say that using a'50% population type criterion, as you propose, would be inappropriate.
The duration of a loss of offsite response capability is as much a factor as its magnitude. If all sirens, for example, are out for routine maintenance for only a few minutes that would not be reportable, but if say a single siren is lost indefinitely without an adequate compensating measure, that would be reportable.
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With regard to question 2 of you'r memorandum, both licensee personnel: and nonlicensee personcel are covered as explained in answer 4.3 of Supphment 1 to NUREG-1022. The main point of the answer 'is that degradation of semerg~ency )
preparedness must be . reported to the FRC regardless of whether that ' degradation is caused by licensen or nonlicensee personnel., We will, however, depend on the licensee's judgment in this matter in order to avoid receiving trivial or ]
meaningless notifications.
With regard to question 3 f your memorandum, we can accept the answer that you propose, but wezwguld prefer that the lictnsee's judgment be used in lieu of a prescriptive 50% threshold for reporting.
With regard to question 4 of your memorandum, we can accept the answer that you propose, but we suggest you refer to answer:4.1 of Supplement .1 to MJREG-1022 for amplification.
With regard to question 5 of your menorandun, both licensee and nonlicensee personnel are covered as explained in answer 4.3 of Supplement 1 to NUREG-1022.
We would expect a notification if, as you suggest, weather prevented activation of the Emergency Response Facility because licensee personnel could not reach .
the plant. We would also expect a notification if the State and local governments s
are rendered incapable of fulfilling their responsibilitiessin the emergency plan for the plant.
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t With regard to your suggestion that we prepare an Information' Notice on this subject, we would propose'to use your questions and our answers in another supplement to NUREG-1022 when we have accumulatec encagh material to justify publishing a new document.
tv, gin.! 5;gn.3 Ivi E. 6 Joeden Edward L. Jordan; Director Division of Emergency Prep'aredness -
and Engineering Response i
Office of Inspection and Enforcement l
Enclosures:
As stated cc w/ encl.: Distribution:
T. T. Martin, RI DCS J. Stohr, RII DEPER R/F 84-111 D R. Bangart, RIV (JAsR/F R. Scarano, RV SSchwartz RDeYoung D. Eisenhut, NRR DMacews JTaylor ERossi KPerkins
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,, ADDITIONAL QUESTIONS AND ANSWERS ON 10 CFR 50.72 1.0 Fords Vs Examples i l'
1.1 reporting requirements of 50.72.It is difficult to instruct c an op '
explanation is by example. The regulations are words, yet the ' f-more examples?
Would it not have been better to have ;
Answer: .
I need amplification in plant procedures.It is may correct that th this supplementary NUREG does, however, contain specific e aThe in x mples.
Comments on the regulations themselves can be submitted at and to shouldtobe be changed submitted assure safety. where a regulation can be improved or me 2.0 Categories of Reports .
2.1 organi7.ations; I hour to the NRC; or as soon a reporting to offsite agencies.
e Can you clarify this? -
Answer':
the regulatory deadlines. Reports'should be made er than as soon as pr ,
more time is permitted for events of less safety significanceDiff 3.0 .
Faragraph 50.72(b)(1)(1)(A) - Initiation of Shutdown 3.1 g Maintenance is required on a safety-related component and result, the component is not available. , as a I operation (LCO) is then entered. A limiting condition for ,
is necessary to reduce power but not to shut downIn order to fix the problem .
Must we report I
via the emergency notification system (ENS) when we reduce power?
Answer: Yes. -
reported If the plant is in a LCO, and must reduce power, it should bc l-the power, reduction may be necessary onlyer to fix a comp than to meet the requirements of the LCO to shut down .
i 4.0 Paragraph 50.72(b)(1)(v) - Emergency Assessment Capability 4 4.1 What is meant by a major loss of emergency assessment ty?
capabili For be example, reportable? would loss of the Safety Parameter Display System inswer:
A major loss of emergency assessment capabilit .
events that significantly impair the licensee'y would include those capa bi l i ty. s safety assessment significance of the loss of particular equipment.Some engineering i SPDS anc other assessment equipment at the same reportable.
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4.2 What is meant by a major loss of of fsite response ,
warrant making an immediate . notification to the NRC?
}l Answer:
A major loss of offsite response capability would include those events that would significantly impair the fulfillment of theAlthough lo licensee's approved emergency plan.
for a short period of time is not a major loss of offsite response capability, the loss of a large number of sirens or more importantly the loss of the capability to alert a large segment of the population for a period of one hour, would warrant an immediate notification.
i 4.3 In the rule as published in the Federal Register, the examples regarding " loss of emergency assessment capability, offsite respons capability, or communications capability" all deal with equipmentMus under the direct control of the licensee.NRC if equipment mai degrades offsite response, emergency assessment or communicat -
capability?
Yes.
If, for example, the alert systems (e.g. sirens), are owned Ansker: and/or maintained by others, the licensee should take reasonable '
measures to remain informed and they Asmust anothernotify' example, the NRC if of a large number of sirens ' fail (see question 4.2),
a large storm or other event causes roads to be closed and the Sta and local governments are rendered incapabl must be notified.
4.4 Suppose that a plant is doing a surveilla'nce instruction ity on its undervoltage protection and the first step is to place the secur computer and emergency communications If the diesel generator f ails andon a back up powe communi-is a diesel generator.
cations with local law enforcement agencies are lost for a minute or two until power is transferred back to the normalbility? bus, should this be reported as a loss of emergency communications capa No.
A momentary loss of emergency communications or offsite response Answer:
capability does not have to be reported.
Radioactivity Releases _
5.0 Paragraph 50.72{b)(2)(vi) 5.1 1 noted stated in thethat rule"as inadvertent" an example which releases of radioactive would require a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> mat notification, irrespective of magnitude, if a news release orIs this correct?
notification to other government agencies is made.
Howev e r ,
! " Answer: The 50.72 4-hour notification was not for although they may be required to be reported to the State.
" routine" releas 4
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, ..a. " routine" release which subsequently received media attention should be reported to the NRC in accordance with 50.72(b)(2)(vi).
The key statement is ".... event or situation related to the health and safety...." Where a State or other government entity has a requirement or agreement with an NRC licensee for routine reporting of other matters, the NRC only requires a report when that. matter i 9ets' escalated to a " news release" of a " situation."
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5.2 If we are required to make routine reports to the Environmental Protection Agency (EPA) regarding routine ef fluent release data, "
are we required to make immediate notification to the NRC?
Answer: No. Routine reports on effluents need not be reported under the 7 immediate notification requirements. If, however, there is a ,
particular effluent release that has safety significance, or is expected to generate public, media, or other agency attention as a result of being unusual or abnormal, then an immediate notification
, to the NRC would be warranted. .
i 5.3 You indicated that some events need not be reported if there is no !
. anticipated press interest. We may not know whether a press release will or will not be issued within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. What should we do?
Answer: A repo~t should be made within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of a decision to issue a' y..
press release. -
5.4 Must the plant notify the NRC per 50.72(b)(2)(vi) when the State incident response facility receives an alarm indication coincident with a control room alarm? For example, an effluent radiation monitor alarms both in the plant control room and at the remote State center, but the actual radiation release is less than the criteria in 50.72(b)(2)(iv).
Answer: Several State incident / emerge.u.y response facilities receive real time alarm indications coincident with alarm conditions at nuclear power f acilities. For example, a hi-radiation alarm for a gaseous effluent radiation monitor would activate alarm indicators at a l ..
remote State facility. The NRC does not consider these alarm l indications as notifications to the State by the licensee. An alarm received at a State facility is in itself not a requirement for notifying the NRC. In so far as this reporting criteria is concerned, the licensee need only notify the NRC when the licensee determines that a reportable release has occurred, or believes a real potential exists for interest on the part of the State, the media, or the public, or a press release is being planned.
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