Text

Event Reporting Guidelines 10 CFR 50.72 and 50.73
	ML20199M068
Person / Time
Issue date:	01/31/1998
From:	Allison D, Harper M, William Jones, Mackinnon J, Sandin S; NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To:	;
References
	FACA, NUREG-1022, NUREG-1022-DRF, NUREG-1022-R01, NUREG-1022-R1, NUREG-1022-R1-DFC, NUDOCS 9802100113
	Download: ML20199M068 (175)
	v • d • e

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Event Reporting Guidelines 10 CFR 50.72 and 50.73 l

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AVAILABILITY NDTICE Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:

1 1.

The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC 20555-0001 2.

The Superintendent of Documents U.S. Government Printing Office, P. O. Box 37082 Washington, DC 20402-9328 3.

The National Technical loformation Service, Springfield, VA 22161-0002 Although the listing that follows represents the majority of documents cited in NRC publica-tions, it is not intended to be exhaustive.

Referenced documents available for inspection and copying for a fee from the NRC Public Document Room include NRC correspondence and internal NRC memoranda; NRC bulletins, circulars, Information noticos, inspection and investigation noticos; licensee event reports; vendor reports and correspondence; Commission papers; and applicant and licensee docu-monts and correspondence.

The following documents in the NUREG series are available for purchase from the Government Printing Office: formal NRC staff and contractor reports, NRC-sponsored conference pro-coedings, international agreement reports, grantee reports, and NRC booklets and bro-chures. Also available are regulatory guides, NRC regulations in the Code of Federal Regula-tions, and IVuclear Regulatory Commission Issuances.

Documents available from the National Technical Information Service include NUREG-series reports and technical reports prepared by other Federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regul.;ory Commission.

Documents available from public and special technical librarios include all open literature items, such as books, journal articles, and transactiors. Federal Register notices, Federal and State legislation, and congressional reports can usually be obtained from these libraries.

Documents such as theses, dissertations, foreign reports and translations, and non-NRC con-forence proceedings are available for purchase from the organization sponsoring the publica-tion cited.

Single copies of NRC draft reports are available free, to the extent of supply, upon written request to the Office of Administration, Distribution and Mail Services Section, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001.

Copies of industry codes and standards used in a substantive manner in the NRC regulatory process are maintained at the NRC Library, Two White 'nt North 11545 Rockville Pike, Rock-ville, MD 20852-2738, for use by the public. Codes and standards are usually copyrighted and may be purchased from the originating organization or, if they are American National Stndards, from the American National Standards Institute,1430 Broadway, New York, NY 10018-3308, t

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NUREG-1022 Rev.1 Event Reporting Guidelines 10 CFR 50.72 and 50.73 Manuscript Completed. December 1997 Date Published: January 1998 Prepared by D. P. Allison, M. R. Ilarper, W. R. Jones, J. H. MacKinnon, S. S. Sandin Omce for Analysis and Evaluation of Operational Data U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 p%,

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Impact This Revision 1 to NUREG-1022 clarifies and consolidates the guidance on implementing the evcnt notification and reporting requirements in 10 CFR 50.72 and 50.73. Little of the guidance is new or different from the generic reporting guidance previously published in final form in NUREG-1022 (1983), its Supplement 1 (1984) and subsequent generic communications.

Where it is different, the changes are minor. In some areas the new guidance will result in fewer reports and in some areas it will result in more reports. On balance, the clarified guidance will result in a small decrease in reporting burden.

PAPEPWORK REDUCTION ACT 5 TATEMENT This report amends the information collections contained in 10 Code of Federal Regulations (CFR) Part 50 and NRC Form 366, Licensee Events Reports. The changes are considered to be insignificant when compared with the overall requirements of the CFR Part and the form (NRC Form 366 reduction of 350 hours0.00405 days 0.0972 hours 5.787037e-4 weeks 1.33175e-4 months annually vs. the current 75K, and 10 CFR 50.72 reduction of 150 hours0.00174 days 0.0417 hours 2.480159e-4 weeks 5.7075e-5 months annually vs. the current 2.4K). NRC does not consider the burder, to be significant enough to trigger the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing requirements were approved by the Office of Management and Budget (OMD), approval number 3150-0011 and 3150-0104.

Public Protection Notification if an information collection does not display a currently valid OMB centrol number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

NUflEG-1027 E ev.1 ii

ABSTRACT Revision 1 to NUREG-1022 clarifies the immediate notification requirements of Title 10 of the Code of Federal Regulations, Part 50, Section 50.72 (10 CFR 50.72), and the 30-day written licensee event report (LER) requirements of 10 CFR 50.73 for nuclear power plants. This revision was initiated to improve the reporting guidelines related to 10 CFR 50.72 and 50.73 and to consolidate these guidelines into a single reference document. A first draft of this document was noticed for public cominent in the Federal Regi,ter on October 7,1991 (56 FR 50598). A second draft was noticed for comment in the Federa/ Register on February 7,1994 (59 FR 5614). This document updates and supersedes NUREG-1022 and its Supplements 1 and 2 (published in September 1983, February 1984, and September 1985, respectively). It does not change the reporting requirements of 10 CFR 50.72 and 50.73.

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5 CONTENTS

- PAPERWORK REDUCTION ACT STATEMENT................................. i1 iii ABSTRACT 4.............................................................

7 EXECUTIVE S U M MARY................................................. lx AC KN OWL E DG M E NTS..................................................... x

- AB B R EVIATI O N S.......................................................... xi 1 I NTR O D U CTI O N........................................................ 1 1.1 B a ckg rou nd.................................................... 1 1.2 Reporting Guidelines and Industry Experience.......................... 2 t-1.3 Revised Reporting Guidelines.................................... 2 1.4 How to Use These Guidelines..................................... 5 1.5 New or Different Guidance.................................... 6 1.6 Planned Future Actions...........,.............................. 6 i

6 2 REPORTING AREAS WARRANTING SPECIAL MENTION

.... 13 2.1 Engineering Judgment...................................... 13 2.2 Differences in Tense Between 10 CFR 50.72 and 50.73..............

. 13 2.3 Multiple Failures and Related Events............

............ 13 4

2.4 Deficiencies Discovered During Engineering Reviews.........

... 14 2.5 Engineered Safety Features Actuations

........ 14 2.6 Events Discussed with the NRC Staff.,.

.......... 14 2.7 Multiple Component Failures..

........ 15 2.6 Dreparation of Licensee Event Reports...

.. 15 2.9 Voluntary Reporting......

............ 15

- 2.10 Retrection/ Cancellation of Event Reports

.,. 16 2.11 Time linihs for Reporting........

.......... 16 2.12 Outside Design Basis......

....... 17 3

3 SPECIFIC REPORTING GUIDELINES.....

...... 19 3.1 Section 50.72 and 50.73 General Requirements...........

........,. 20 3.1.1 Immediate Notification Requirements......................... 20

. 3.1.2 Licensee Event Report System.............................. 22 3.2 One-hour EtlS Notifications and 30-Day LERs........................ 23 3.2.1 Plant Shutdown Required by Technical Specifications

. 24 3.2.2 Technical Specification Prohibited Operation or Condition.......... 27 3.2.3 Technical Specification Deviation per $50.54(x)................. 33 v

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2-t 3.2.4 Operating Plant Found in Degraded or Unanalyzed Condition....... 34 L

3.2.5 External Threat to Plant Safety............................ 41 3.2.6 ECCS Discharge into the Reactor Coolant System............ 45 3.2.7 Lost af Emergency Preparedness Capabilities................... 47 3.2.8 Internal Threat to Plant Safety........,,.................. 51 3.3 Four-hour ENS Notifications and LERs.....

...... 54 -

3.3.1 Shutdown Plant Found in Degraded or Unanalyzed Condition....... 55

- 3.3.2 Actuation of an Engineered Safety Feature or the RPS........... 57 3.3.3 Event or Condition That Alone Could Prevent Fulfillment of a Safety i

Fu nction..................

....................,65 3.3.4 Common-cause Failures of Independent Trains or Channels....... 80 3.3.5 Airborne or Liquid Effluent Release.

..... 84 i

. 3.3.6 Contaminated Person Requiring Transport Offsite................ 87 3.3.7 News Heiease or Other Government Notifications

........,,. 88 3.3.8 Spent Fuel Storage Cask Notifications..

.......,. 92 4

3.4 Followup Notification........

.............. 93 r

1 4 EMERGENCY NOTIFICATION SYSTEM HEPORTING,............

.95 4.1 Emergency Notification System....

. 95 4.2 General ENS Notification.........

. 96 4.2.1 Timeliness......

................ 96 4.2.2 Voluntary Notifications

.. 96 i

4.2.3 ENS Notification Retractio :

. 96 4.2.4 ENS Event Notification Worksheet (NRC Form 361)............ 96 4.3 Typical ENS Reporting Issues.

............,97 5 LICENSEE EVENT REPORTS......

.. 99 5.1 LER Reporting Guic;elines..........

....... 99 5.1.1 Submission of LERs....

....... 99 5.1.2 LER Forwarding Letter and Cancellations.................. 99 5.1.3 Report Legibility

. 100 5.1.4 Exemptions...

.. 100 5.1.5 Voluntary LERs......

100 5.1.6 SupplementalInformation and Revised LERs......

101 5.1.7 Special Reports.........

....... 101 5.1.8 Appendix J Reports (Containment Leak Rate Test Reports).

.102 5.1.9 10 CFR Part 21 Reports................

102 5.1.10 Section 73.71 Reports

... 103 5.1.11 Availability of LER Forms

.... 103 5.2 LER Content Requirements and Preparation Guidance.........

.103 5.2.1 Narrative Descrip; ion or Text (NRO Form 366A, item 17)....

105 5.2.2 : Abstract (NRC Form 366, item 16)....

............... 114 5.2.3 Other Fields on the LER Form.

......... 1 14 NUREG-1022, Rev.1 vi

APPENDICES A Historical Perspective on Event Reporting

B Emergency Notification System Process-C Licensee Event Report Review Programs -

- D.10 CFR 50.72 including Statement of Considerations E 10 CFR 50.73 including Statement of Considerations F 1992 Revision to 10 CFR 50.72 and 50.73 Including Statement cf Considerations TABLES i

1. Comparability of 10 CFR 50.72 and 50.73 Criteria............................. 7

2. E x a m ple S y st e m s.................................................

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EXECUTIVE

SUMMARY

Two of the many elements contributing to the safety of nuclear power are emergency response and the feedback of operating experience into plant operations. These are achieved partly by the licensee event reporting requirements of Title 10 of the Code o/ Federa/ Regulations, Part 50, Sections 50.72 and 50.73 (10 CFR 50.72 and 50.73), which became effective on January 1, 1984. Section 50.72 provides for immediate notification requirements via the emergency notification system (ENS) and Section 50,73 provides for 30-day written licensee event reports (LERs).

The information reported under 10 CFR 50.72 and 50.73 is used by the NRC staff in responding to emergencies, monitoring ongoing events, confirming licensing bases, studying potentially generic safety problems, assessing trends and patterns of operational experience, monitoring performance, identifying precursors of more significant events, and providing operational experience to the industry.

Expenence has shown that the threshold for reporting has not been consistently implemented and some problems exist with the interpretation of the guidelines and definitions. A 1990 survey on the effect of NRC regulation on nuclear power plant activities and subsequent event reporting workshops also indicated a need for further guidance on the two reporting rules.

Therefore, the NRC staff prepared NUREG-1022, Revision 1, which clarifies implementation of the existing 10 CFR 50.72 and 50.73 rules and consolidates important NRC reporting guidelines into one reference document. The clarifications include major editing of the previous i

guide'ines. The document is structured to assist licensees in achieving prompt and complete reporting of specified events and conditions. The revised guidelines are not expected to result I

in a significant change in the annual industry-wide total numbers for ENS notifications and LERs. The effect on individual licensees is expected to vary.

The document addresses general issues of reporting that have,ot been consistently applied and covers such diverse subjects as engineering judgment, mumple failures and related events, deficiencies discovered during licensee engineering reviews, and human performance issues.

The guidelines for specific reporting criteria have been enhanced by improved discussions of j

concepts, thresholds, and illustrative examples; definitions of key terms and phrases; and original ENS guidelines for some criteria that were not previously addressed. A new section has been added that discusses ENS communications and methods, voluntary reporting, retraction of reports, importance of reporting timeliness and completeness, and typical NRC 1

concerns associated with ENS notifications for each reporting requirement.

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ACKNOWLEDGMENTS The authors Revision 1 wish to acknowledge the members of the task group that prepared the first draft of Revision 1: John Boardman, Paul Bobe, Marcel Harper, John Crocks, L. Mark Padovan, and Robert Spence of the U.S. Nuclear Regulatory Commission (NRC) Office for Evaluation and Operation of Operational Data (AEOD).- They were assisted by Roger Woodruft of the NRC Office of Nuclear Reactor Regulation (NRR) and Eric Weiss and Aimee Brown of AEOD. With regard to the second draft and this final version, the authors wish to acknowledge the contributions of Sanford Israel and Shirley Rohrer of AEOD.. With regard to the final draft the authors also wish to ackriowledge the assistance of David Skeen of NRR, Milton Vagins of

- the NRC Office of Nuclear Regulatory Research, and representatives of the NRC's four regional offices, Gordon Hunegs (RI), Charles Ogle (Ril) Edward Schweibinz (Rlll) and Michael Runyan (RIV). Dee Gable of the NRC Office of Administration (ADM) reviewed the first two drafts.

Geary Mizuno of the NRC Office of the General Counsel (OGC) reviewed both drafts and the final version.

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l ABBREVIATlONS AEOD Analysis and Evaluation of Operational Dab, Office for AIT augmented inspection team ASME American Society of Mechanical Engineers ASP accident sequence precursor ATWS anticipated transient without scram BPV Boiler and Pressure Vessel Code (ASME)

BWR boiling-water reactor CFR Code of FederalRegulations CRDM controi rod drive mechanism CRVS control room ventilation system DBCR design-basis documentatioa review DDR design document reconstitution ECCS emergency core cooling system EDG emergency diesel generator Ells Energy industry identification System ENS emergency notification system EO emergency officer EOF emergency operations facility EOP emergency operating procedu;e EPIX equipment performance and information exchange EPA Environmental Protection Agency (U.S.)

ERDS emergency response data system ERF emergency response facility ESF engineered safety feature (s)

ESW emergency service water FEMA Federal Emergency Management Agency FFD fitness for duty FSAR final safety analysis report FTS federal telecommunications system GDC general design criteria GL generic letter HOO neadquarters operations officer xi NUREG-1022, Rev.1

HP health physs HPCI high-pressure coolant injection HPl high pressure injection

~HPN

. health physit,s network HPSI high pressure safety injection.

HVAC heating, ventilation and air conditioning IEEE Institute of Electrical and Electronics Engineers llT.

incident investigation team ILRT integrated leak rate test IN information notice INPO Institute of Nuclear Power Operations ISI inservice inspection IST inservice testing ISTS improved standard technical specifications LCO limiting condition for operation LER licensee event report LOCA loss of coolant accident LPSW low pressure service water MPC maximum permissible concentration MSIV main steam isolation valve NPRDS nuclear plant reliability data system NRC Nuclear Regulatory Commission (U.S.)

NRR Nuclear Reactor Regulation, Office of NUMARC Nuclear Management and Resources Council OCR optical character reader OMS overpressure mitigation system POR Public Document Room PGA policies, guidance, and administrative controls PWR pressurized water reactor RAB Reactor Analysis Branch RBVS reactor building ventilation system RCIC reactor core isolation cooling RCP reactor coolant pump RCS reactor coolant system RDO regional duty officer RHR residual heat removal RPS' reactor protection system RWCU

reactor water cleanup SALP.

systematic assessment of licensee performance NUREG-1022, Rev.1

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safety analysis report SAR:

- S/D

- shutdown SIS _

. safety injection system SOV:--

- solenoid-operated valve.

SPDS safety parameter display system

-SRO senior reactor operator STS standard technical specifications

-TS

. technical specification (s)

TSC technical support center 5.

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1 INTRODUCTION This document provides guidance on the reporting requirements of Title 10 of the Code of Federa/ Regulations, Part 50, Sections 50.72 and 50.73 (10 CFR 50.72 and 10 CFR 50.73).

While these reporting requirements range from immediate,1-hour, and 4-hour verbal notifications to 30-day written reports, covering a broad spectrum of events from emergencies to generic component level deficiencies, the NRC wishes to emphasize that reporting requirements should not interfere with ensuring the safe operation of a nuclear power plant.

Licensees'immediate attention mest always be given to operational safety concerns.

1.1 Background

The origins of 10 CFR 50.72 and 50.73 are described in Appendix A to this report. In 1983, partially in response to lessons from the Three Mile Island accident, the U.S. Nuclear Regulatory Commission (NRC) revised its immediate notification requirements via the emergency notification system (ENS) in 10 CFR 50.72 and modified and codified hs written licensee event report (LER) system requirements in 10 CFR 50.73. The revision of 10 CFR 50.72 and the new 10 CFR 50.73 became effective _on January 1,1984. Together, they specify the types of events and conditions reportable to the NRC for emergency response and identifying plant-specific and generic safety issues.

The two rules have identical reporting thresholds and similar longuage whenever possible.

They are complementary and of equalimportance, with necessary dissimilarities in reporting requi'ements to meet their different purposes, as illustrated in this report, Section 1, Table 1, and Section 3 text.

Section 50.72 is structured to provide telephone notification of reportable events to the NRC Operations Center within a time frame established by the relative importance of the events.

Events are categorized as either emergencies (immediate notifications, but no later than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) or non emergencies. The latter is further categorized into 1-hour and 4-hour notifications; non-emergency events requiring 4-hour notifications generally have slightly less urgency and safety significance than those requiring 1-hour notifications. Immediate telephone notification to the NRC Operations Center of declaced emergencies is necessary so the Commission may immediately respond. Reporting of non-emergency events and conditions is necessary to permit timely NRC followup via event monitoring, specialinspections, generic communications, or resolution of public or media concerns.

Section 50.73 requires written LERs to be submitted on reportable events within 30 days of their occurrence, after a thorough analysis of the event, its root causes, safety assessments, and corrective actions are available, to permit NRC engineering analyses and studies.

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Some reporting guidance for 10 CFR 50.72 and 50.73 was conta;ned in the Statements of Considerations for the rules. More detailed guidelines and examples of reportable events were developed and issued in NUREG-1022 and its Supplements 1 and 2. The intent of these publ cations was to achieve complete reporting of specified events and conditions.

Subsequently, additional interpretations and directions on certain subjects have been issued in NRC bulletins, information notices, and generic letters.

1.2 Reporting Guidelines and Industry Experience Event reporting under these rules since 1984 has contributed significantly to focusing the attention of the NRC and the nuclear industry on the lessons leamed from operating experience to improve reactor safety. In the mid-1980's, decreasing trends in the number of reactor transients and in the number of t,ignificant events and improvements in reactor safety system performance were noticeable. Since 1989, these trends have leveled off as fewer plants were on a learning curve and industry completed improvements that have a high return in safety performance. While the more obvious lessons have been extracted from operating experience, more analyses need to be performed and new efforts need to be developed to extract further lessons from operational data.

The operational experience submitted in accordance with 10 CFR 50.72 and 50.73 is publicly available and has been used by other organizations in ways that are most often beneficial to nuclear safety. However, uees in areas that were unintended, such as in prudence hearings, in statistical presentations and comparisons of reporting rates without regard to or inclusion of a technical analysis of the safety significance of the events, can lead to unwarranted impressions of safety performance. In such uses, there has been a tendency to only count the number of reported events without assessing their individual safety significance. Such misuses could result in licensees adopting a more restrictive reporting threshold in order to reduce the number of reportable events, although the Commission's requirement for a low threshold has not changed. This can be counterproductive to the purpose of these rules.

Experience has shown that the threshold cf reporting, as well as other areas of the reporting rules, has not been consistently implemented. Some problems have occurred in such areas as interpretation of the guidelines and def;nitions, timeliness of reporting, reporting of generic concerns, engineering judgment, and reporting of deficiencies found during design reviews.

These problems, as well as a 1990 survey on the effect of NRC regulation on nuclear power plant activities and subseauent event reporting workshops, identified the need for further guidelines on the two reporting rules.

1.3 Revised Reporting Guidelines The purpose of this revision to NUREG-1022 is to ensure events are reporteri as required by improving 10 CFR 50.72 and 50.73 reporting guidelines and to consolidate thess guidelines into a single reference document. This document updates and supersedes NUREG-1022 and its Supplements 1 and 2.

An NRC task group prepared this docuraent principally by editing and combining the information contained in NUREG-1022 and its Supplements 1 and 2, the Statements of Considerations for NUREG-1022, Rev.1 2

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10 CFR 50.72 s nd 50.73, other NRC staff documents on event reporting (such as information notices, bulletins, inspection manual chapters, enforcement actions, letters and memoranda),

ENS event notification reports, and LERs. A second task group prepared the second draft of j

this document, orincipally by considering the public comments received and the requirements of i

the rules, their Statements of Considerations, and previous NRC generic guidance on reporting.

Ir; compiling this document, the information in NUREG-1022 was edited for clarity. The paragraph-by paragraph explanation of the LER rule, which was a restatement of guidance in the Statement of Considerations, was presen/od or more thoroughly discussed. Most of the examples were ieplaced with others that have been condensed to exemplify specific reporting thresholds.

Most of the specific questions and answers on both rules as contained in NUREG-1022, Supplement 1, were incorporated as generic statements into the d;scussions or examples in Sections 2,3,4, and 5 of this documet. The ENS and LER rules are compared side-t v-side in Section 3.

NUREG-1022, Supplement 2, made recommendations for improvements in LER quality; Appendices B and D of Supplement 2 were incorporated into the discussions in Section 5.2 of this document.

In addition, experience from responding to NRC staff and licensee inquiries in various event reporting workshops since 1984 and ENS calls has been considered in tHs report. Many actual events were summarized to exemplify event reportability in response to licensea requests. The principal NRC staff involved in the original codification and revisions to 10 CFR 50.72 and 50.73 were consulted regarding the originalintent ci the regulations.

Section 2 clarifies specific areas of 10 CFR 50.72 and 50.73 that are applicable to many reporting criteria or that historically appear to be subject to varied interpretations. It covers such diverse subjects as engineering judgment, differences in tenses between the two rules, retraction and voluntary reporting, legal reporting requirements, and human performance issues.

Section 3 contains guidelines on event reporting for specific critena in both rules by means of discussions and examples of reported events. To minimize iepetition, similar criteria from ooth rules are addressed together. The format follows the order of 10 CFR 50.72 with 50.73 appropriately interwoven.

Section 3.1 addresses general methods of ENS reporting for declared emergencies and non-emergencies. Practical guidelines are given on making ENS emergency notifications.

Requirements for LER reporting regardless of plant mode, power level, or the significance of an initiating item are specified.

Section 3.2 addresses ENS 1-hour reporting criteria and 30-day LERs. The existing mNS and LER guidelines related to plant shutdowns required by technical specificatio 'TS), TS deviations per $50.54(x), and TS prohibited operations or conditions are reiterated. Plant operation in a degraded or unanalyzed condition, or outside the plant's onerating and 3

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emergency procedures, is clarified by definitions and examples. The timing of ENO reporting of anticipated natural phenomenon or conditions threatening plant safety is explained to ensure good communication between licensees and the NRC during developing situations. Valid emergency core cooling system (ECCS) discharges into the reactor coolant system are defined and invalid ECCS discharges are identified as reportable within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months as an engineered safety feature (ESF) actuation. Additional guidelines and thresholds are given on the ENS reporting of the loss of emercency assessment, response, or communications. The intent of the reporting criteria on internal plant safety throats, including such examples as fire, toxic gas, or radiation releases, is explained to also include any other internal safety threat. Floods and spills are discussed as another typical threat to plant safety and the terms " threat" and "significant hampering of site personnel" are defined.

Section 3.3 addresses Ohour ENS notificatioris and 30-day LERs. Examples are provided for degraded or unanalyzed conditions found while the plant is shut down. Engineered safety feature and reactor protection systems actuations are discussed. Anticipated transient without scram (ATWS) system actuations are addressed. The 1992 revisions to 10 CFR 50.72 and 50.73 that reduced the reporting of engineered safety features actuations are also discussed.

Terms are defined regarding the reporting criteria for events or conditions that alone could have prevented fulfillment of the safety function required for shutdown of the reactor, removal of residual heat, release of radioactive material, or mitigation of the consequences of an accident.

Single, common-mode, and multiple independent failures reportable under this criterion are discussed. The discussion of LER reporting of common-mode failures of independent safety system trains defines a numbe of terms and notes their importance as precursors. The existing ENS and LER ge : lines related to airborne or liquid releases are restated. Guidelines are clarified on ENS reporting of a contampated person requiring transport to an offsite medical facility. The basis and report timing for the UNS reporting criteria regarding news releases or other government notifications are explained, as necessary, so that the NRC can appropriately respond to media or govemment inquiries and thresholds for reporting are clarified. The recently issued ENS reporting criterion regarding spent fuel storage cask problems is included.

Sectico 3.4 addresses the requirements for immediate ENS followup notifications during the cour'ie of an event. The requirement, means, and methods to maintain continuous or periodic corr munication with the NRC during events, if so requested, are explained.

Section 4 explains ENS communications (from existing information notices), reporting timeliness and completeness, vo!untary notifications, and retractions. Appropriate ENS emergency notification methods are described.-

Section 5 reiterates previous guidelines on administrative requirements, preparation, and submittal of LERs. It specifies the information an LER should contain and provides steps to be followed in preparing an LER. It also includes an expanded human performance discussion to achieve ENS and LER content that examines both equipment and human performance.

Appendix A provides the history of 10 CFR 50.72 and 50.73, associated NRC workshops, and an NRC regulatory impact study, which was one of the factors leading to this document.

NUREG-1022, Rev.1 4

Appendix B discusses the key NRC ENS personnel, range of NRC responses to ENS notifications, and NRC event review.

Appendix C addresses the NRC LER analysis and evaluation programs and other uses of LERs nationally and internationally.

Appendix D contains 10 CFR 50.72 including its Statement of Considerations as published in the Federal Register.

Appendix E contains 10 CFR 50.73 including its Statement of Considerations as published in the FederalRegister.

Appendix F conta!ns 1992 revisions to 10 CFR 50.72 and 10 CFR 50.73 including the Statement of Considerations as published in the Federa/ Register.

1.4 How to Use These Guidelines Th!s NUREG was designed primarily as a reference to help licensees determine event reportability, make ENS notifications, and prepare and submit LERs.

Reportability Determinstion The applicable 10 CFR 50.72 and 50.73 repurting criteria are identified in the Table of Contents of this report, as well as in the respective rules. Because these rules have overlapping reporting requirements, it is not unusual t' find an event reportable under more than one criterie. A reportable event is to be reported under the most immediate reporting requirements.

Generally, many events and conditions that require an ENS notification also require the submittal of an LER, as reflected by many of the rules' parallel reporting requirements.

The reporting determination guidelines in Section 3 for both 10 CFR 50.72 and 50.73 are presented together wherever possible in the " Discussion" and " Example" explanations for each paragraph. The differences between the ENS and LER reporting requirements are underlined. The differences are discussed when they are important.

Key terms are defined and important concepts are identified in the " Discussion" sections Events used as examples may be reportable under other criteria but are usually only evaluated for reportability under the specific criteria they appear under.

General issues, such as timeliness, can also be found in Section 2.

Other reporting requirements applicable to operating reactors include 10 CFR 50.9, 20.2202,20.2203,50.36,72.74,72.216,73.71, and Part 21. When reports are required under these iequlations, some parts require the use of 10 CFR 50.72 and 50.73 notifications and written reports. Duplicate reporting is not required.

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ENS Notification

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Once an event has been determined to be reportable under 10 CFR 50.72, an ENS notification is to be made. The ENS notification time limit can be found under the applicable 950.72 criteria in Section 3; if more than one reporting criterion applies, the shortest time limit should h met. Guidelines on the information to be reported may be found in Section 4.3. Practical information regarding the actual telephone call can be found in Sections 4.1 and 4.3.

LER Preparation and Submittal Once an event has been determined to be reportable under 10 CFR 50.73, an LER is to be prepared and submitted. Administrative requirements and guidelines for submitting LERs can be found in Section 5.1. The requirements and guidelines for the cc.1 tent of LERs can be found in Section 5.2.

1.5 New or Different Guidance Reporting guidance that is considered to be new or different in a meaningfu! way, relative to previously published generic reporting guidance, is indicated by shading the appropriate text.

Occasionally, text is marked by both redline and strikeout in order to show that specific items are being deleted.

1.6 Planned Future Actions The NRC staff recognizes a need to revise the reporting requirements in 10 CFR 50.72 and 50.73 to better align them with the NRC's current needs, including the move toward risk-informed regulation and reporting of design basis issues. Accordingly, the staff plans to develop a rulemaking plan and proceed expeditiously with rulemaking to accomplish these ends. However, rulemaking will take time, whereas the work on this document has been completed. Thus, it is considered worthwhile to issue this revision to NUREG-1022 to provide improved guidance now. In the future, as rule changes are developed, new guidance will be developed concurrently.

NUREG-1022, Rev 1 6

Table 1 Cornparability of 10 CFR 50.72 cnd 50.73 Cntena ENS notfication as soon as ENS notification as soon as 30-day LER NUREG Event or Condition pracbcal and in all cases practcal and in all cases Sect within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months EMERGENCY CLASS Immediately a*ter notification of Note-Arthough not speafically 3.1.1 State and local authorities, but mentioned in 10 CFR 50.73, no later than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after many emergency class events declaration of emergency class involve reportable situations deined in licensee's emergency plan [50.72(a)(1),(a)(2),(a)(3) and (a)(4)]

TECHNICAL SPECIFICATIONS (TS):

N Plant shutdown (S/D) required by Initidion of S/D required by TS Completion of S/D required by 3.2.1 2

TS'

[5032(b)(1)(1)(A)]

TS[50.73(a)t )(1)(A)]

Operation or condition 3.2.2 TS prohibited operations or prohibited by TS conditions

[50.73(a)(2)(1)(B)]

I TS deviation authorized by Deviation from TS authorized by 3 Cnterion [50.73(a)(2)(1)(C)]

3.2.3 a

50.54(x) 50.54(x)[50.72(b)(1)(1)(B)]

same as ENS 1 hour DEGRADED CONDITION; UNANALYZED CONDITION,

[

OUTSIDE DESIGN BASIS.

m NOT COVERED BY PROCEDURES:

o Plant, incluo? a its principal safety During opetation, serious Found while shut down; had it Either in operation or SO.

3.2.4

~U barri3rs, seriously deg aded degradation of plant including its been found in operation, would condition of plant, including 3.3.1 principal safety barriers have been seriously degraded principal safety barriers, ge

[50.72(b)(1

[50.72(b)(2)(1)]

seriously degraded

[50.73(a)(2)(ii)]

a

ZC W

Table 1 (continued)

-f

-y ENS not:fication as soon as ENS notficabon as sorM as NUREG Event or Condition practical and in all cases prac" cal and in a:1 cases 30 day LER Sect-

[

within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months t

t l

DEGRADED...(CONTINUED):

Plant in unanalyzed condition Dunng operation, plant in Found while shat down; had it Either in operation or S/D.

3 2.4, significantly compromising plant unanalyzed cond! tion, been found in operation, would unanalyzed condstK,n 3.3.1 safety significantly compromising plant have been unanalyzed condition significantly compromising safety [50.72(b)(1)(ii)(A)]

that significantly compromises plant tafety [50.73(a)(2)(ii)(A)]

plant safety [50.72(b)(2)(1)]

Plant outside design basis of plant During operation, plant in Whiie either in operation or 3.2.4 condition outside design basis S/D, plant was in condition 3.3.1

[50.72(b)(1)(ii)(B)]

outside design basis c

[50.73(a)(2)(u)(B)]

Plant in condition not covered by During operation, plant in While either in operation or 3.2.4.

operating and emergency condition not covered by j

S/D nt=% % cnEn not 3.3.1 procedures operating and emergency I

covered by operating and procedures [50.72(b;G',69tC)]

eincipi,cy procedures

[50.73(a)(2)(ii)(C)]

j EXTERNAL TMP. EAT TO PLANT Any natural phenomenon Or Criterion [50.73(a)(2)(iii)]

3.2.5 SAFETY other extemal condition that same as ENS 1 hour poses an actual threat M the safety of the plant or significantly hampe;s site personnelin performance of duties necessary for its safe operation [50 72(b)(1)(ni)]

EMERGENCY CORE COOLING A valid ECOS signal that results.

Manual or automatic actuation Criterior. *30.73(a)(2)(iv)]

32.6 i

SYSTEM (ECCS) DISCHARGE; or should have resulted,in of any ESF, including the encompasses both ENS 1 3.3.2 ACTUATION OF ANY ECCS discharge into the reactor reactor protection system hour and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ENGINEEHED SAFETY (ESF) coolrnt system [50.72(b)(1)(iv)]

(RPS), occurs and was not a

preplanned as part of a test or i

reactor operation I50.72(b)(2)(ii)1

b i

Table 1 (continued)

I t

ENS notfication as soon as ENS isLTwbun as soon as NUREG' Event or Condition practical and in all cases practical and in all cases 30L4ay LER Sect within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months i

EVENT THAT ALONE COULD Event or condition alone would Criterion [50.73(a)(2)(v)] same 3.3.3 HAVE PREVENTED have prevented fulfillment of as ENS 4 hours. Need not FULFILLMENT OF A SAFETY safety funcbon of system report individual wii.yarent FUNCTION needed for S!D of the reactor, failures under this paragraph maintenance of a safe S/D if redundar.1 equipment in condition, residual heat removal same system was operable (RHR), control of release of and available [50.73(a)(2)(vi)]

radioactive material, or mitigation of the consequences of an accident [50.72(b)(2)(iii)]

e COMMON CAUSE OR Single cause or condition 3.3.4 CONDITION RESULTING IN caused inoperability of at i

INCEPENDENT TRAINS OR least one independent train or CHANNELS BECOMING channet in multiple systems or

[

INOPERABLE two independent trains and 1

channels in a single system designed for safe S/D, RHR.,

radiation release control, or accident mitigation

[SO.73(a)(2)(vii)]

[

b RADIOACTIVE RELEASES:

x Airbome radioactivity releases Airbome radioactivity released Criterion [50.73(a)(2)(viii)(A)]

3.3.5 la to an unrestricted area exceeds -

same as ENS 4 hours.

S 20x the concentration specified N

in 10 CFR 20 Appendix B, m

Table 2, averaged over 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months y

[50.72(b)(2)(iv)(A)]

_a

ZC 23 rn O

a Table 1 (contnued)

'8

-M ENS notification as soon as ENS not. cation as soon as NUREG f

Event or Condition practical and in a!! cases pracbcal and in all cases 30-day LER 3ect 5

within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months wdhin 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months RELEASES (CONTINUED):

Liquid effh tent releases Liquid effluent released to an unrestricted area e-ceeds 20x the concentration specified in 10 Criterion [50.73(a)(2)(viii)(C)]

CFR 20, Appendix B. Table 2, sarne as ENS 4 hours.

3.3.5 for all radionuclides except tritium and dissolved noble gases, averaged over 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

[50.72(b)(2)(~rv)(B)].

I o

INTERNAL THREAT TO PLANT Any event that poses an actual Crrterbn [5033(a)(2)(x)] same 3.2.8 SAFE 1Y threat to the safety of the plant as ENS 1 hour or significantly hampers site personnelin the conduct of safe operation [50.72(b)(1)(vi)]

LOSS OF EMERGENCY A major loss of capabihty occurs 3I ASSESSMENT, OFFSITE for emergency assessment, RESPONSE, OR offsite response, or i

COMMUNICATIONS communcations [50.72(b)(1)(v)]

CAPABILITY TRANSPORT OF A radioactively contaminated 3.3.6 CONTAMINATED PERSON TO person is transported to an OFFSITE MEDICAL FACILITY offsite medical facilrty

[50.72(b)(2)(v)]

r i

Table 1 (continued) l ENS notificabon as soon as ENS not$cahon as soon as NUREG Event or Condtion pracbcal and in as cases pracbcal and in as cases 30 day LER Sect.

within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months NEWS RELEN DTHER A news release is planned or 3.3.7 GOVERNMEU NOTIFICATIONS other govemment agencies have been or wil be notified of an event related to the health and safety of the public or onsite personnel, or the p NK: bon of the environment [50.72(bX2Xvi)

DEGRADED SPENT FUEL A defectin any spent fuel storage 3.3.8 STOCAGE CASK OR cask

tructure, system, or

- CONhNEMENT SYSTEM compw that is iment to a

safety [50.72(bX2XviXA)]. A segn6 cant reduction in the effechveness of any spentfuel storage cask confinement system during use of the storage cask under a generallicensee issued ui. der 10 CFR 72.210

[50.72(bX2XvD(B)]

E Z

FoBowup Notificahon (Section 3.4):

C After making a ' -our or 4-hour notrficabon, licensees are required to immediately notify the NRC Operations Center if any of the fogownng occam y

plant condrtions worsen [50.72(c)(1XI)], emergency class 6cahon changed [50.72(cX1Xi)], or emergency ciaes termmated [50.72(cX1Xs));

e the results of ensuing evaluations or assessments of plant condeons are obtained [50.72(cX2XI)],

o e

la e

the effectiveness of response or protective measures taken becomes knowr. [50.72(cX2Xi)l; information related to plant behavior is not understood [50.72(cX2XE)};

e N

in addition, if requested by the NRC, maintain an open, continuous communicahon channel

the NRC Operabons Center [50.72(cX3)].

?

a

2 REPORTING AREAS WARRANTING SPECIAL MENTION This section clarifies specF.: areas that are applicable to many reporting criteria or that historically appear to be subject to varied interpretations.

2.1 Engineering Judgment J

The reportability of many events and conditions is self evident. However, the reportability of other events and conditions may not be readily apparent and the use of engineering judgment is involved in determining reportability.

Enginee:ing judgment may include eitner a documented engineering analysis or a judgment by a technically qualified individual, depending on the complexity, seriousness, and nature of the event or condition. A documenu.i engineering analysis is not a requirement for all events or conditions, but it would be appropriate for particularly complex situations. In addition, although not required by the rule, it may be prudent to record in writing that a judgment was exercised by identifying the individual making the judgment, the date made, and briefly documenting the basis for this judgment. In any case; the' staff considers that the usc'of engine _ering judgment impies~a logical thought process that supports the judgment!

2.2 Differences in Tense Between 10 CFR 50.72 and 50.73 The present tense was used in 10 CFR 50.72 because the event or condition generally would be ongoing at the time of reporting. The past tense was used in 10 CFR 50.73 because the event or condition normally would be past when an LER was written.

This ditierence creates some confusion over the reportability under 10 CFR 50.72 of events not related to an ongoir o event or discovered as the result of an event review. In other cases, questions are raised regarding the need for a 10 CFR 50.73 report. Where the tense is relevant to reportability, it is addressed in the specific criterion in Section 3 of this report.

2.3 Multiple Failures and Related Events More than one failure or event may be reported in a single ENS notification or LER if (1) the failures or events are related (have the same general cause or consequences) and (2) they occurred during a single activity (e.g., test program) over a reasonably short time (within the ENS reporting time limit for ENS reports, or within the first 30 days of discovery of the first reportable event for LER reporting).

For an outage that lasts longer than 30 days, such as 60 days, similar events that are part of the ssme activity or test program and are therefore related may be reported as a single LER.

13 NUREG-1022, Rev.1

To the extent feasible, report failures that occurred within the first 30 days of discovery of the first failure en ons LER. State in the LER text that a supplement to the LER will be submitted when the test is completed. Include all the failures, including those reported in the original LER, in the revised LER (i.e., the revised LER should stand alonel Generally, LERs are intended to address specific events and plant conditions. Thus, unrelated events or conditions should not be reported in one LER. Also, an LER revision should not be used to re7 ort subsequent failures of the same or like components that are the result of a different r.ause or for separate events or activities.

Unrelated iailures or events should be reported as separate ENS lotifications to be given unique GNS numbers by the NRC. However, multiple ENS notifications may be addressed in a single telephone call.

2.4 Deficiencies Discovered During Engineering Reviews or inspections As indicated in NUREG-1397, "An Assessment of Design Control Practices and Design Reconstitution Programs in the Nuclear Power industry," February 1991, Section 4.3.2, the reporting requirements specified in 10 CFR 50.9, 50.72, and 50.i3 apply equally to discrepancies discovered during design document re':onstitution (DDR) programs, design-bases documentation reviews (DBDRs), and other si,,,;lar engineering reviews. There is no basis for treating discrepancies discovered during such reviews differently from any other reportable item.

Licensees should evaluate the reportability of suspected but unsubstantiated discrepancies discovered during such a review program in the same manner as other potentially reportable items. See Section 2.11 for discussion of reporting time limits and discovery dates.

2.5 Engineered Safety Features Actuations Systems typically. reported under this crite' ion include the systems listed in Table 2.':The NRC staff considers these systems to be a reaaonable interpretation of what constitutes systems "provided to mitigate the consequences of a stui.ificant event? Further guidance beyond that provided in this revision is being deferred pending rulemaking to address issues such as whether the rule should list specific cystems or provide general guidance. See Section 3.3.2 for further discussion of this matter.

2.6 Events Discussed with the NRC Staff Some licensee personnel have erroneously believed that if a reportable event or condition had been discussed with the resident inspector or other NRC staff, there was no need to report under 10 CFR 50.72 and 50.73 because the NRC was aware of the situation. Some licensee personnel have also expressed a similar understanding for cases in which the NRC staff identified a reportable event or condition to the licensee via inspection or assessment activities.

Such means of repc iing do not satisfy 10 CFR 50.72 and 50.73. The requirement is to report to the ENS and LER systems events or conditions meeting the criteria stated in the rules.

NUREG-1022, Rev.1 14 i

2.7 Maltiple Component Failures There have been cases in which licensees have not reported multiple, sequentially discovered failures of systems or components occurring during planned testing. This situation was identified as a generic concem on April 13,1985, in NRC Information Notice (IN) 85-27,

" Notifications to the NRC Operations Center and Reporting Events in Licensee Event Reports,"

regarding the reportability of multiple events in accordar'ce with 950.72(b)(2)(iii) and 50.73(a)(2)(v)(event or condition that alone could prevent fulfillment of a safety function). (This reporting criterion is discussed in Section 3.3.3 of this report.)

IN 85-27 described multiple failures of a reactor protection system during control rod insertion testing of a reactor at power. One of the control rods stuck. Subsequent testing identified 3 additional rods that would not insert (scram) into the core and 11 control rods that had an initial hesitation before insertion. The licensee considered each failure as a single random failure; thus each was determined not to be reportable. Subsequent assessments indicated that the instrument air system, which was to be oil free, was contaminated with oil that was causing the scram solenoid valves to fail. While the failure of a single rod to insert may not cause a reasonable doubt that other rods would fail to insert, the failure of more than one rod does cause a reasonable doubt that other rods could be affected, thus affecting the safety function of the rods.

As indicated in IN 85-27, multiple failures of redundant components of a safety system are sufficient reason to expect that the failure mechanism, even though not known, could prevent the fulfillment of the safety function.

2.8 Preparation of Licensee Event Reports (LERs)

This revision _ includes new guidance to address consistency of information provided in LERs which is used to understand reported events. Some of this guidance was not specifically addressed in the second draft that was published for comment. It is included to help ensure that consistent information is provided regarding human factors analysis and risk-informed regulatory programs such as accident sequence precursor (ASP) analysis and equipment reliability estimates. It doet not affect the decision as to whether or not an event must be reported. See Section 5 for further discussion.

2.9 Voluntary Reporting Information that does not meet the reporting criteria m 10 CFR 50.72 and 50.73 may be reportable under other requirements such as 10 CFR 60.9,20.2202,20.2203,50.36,72.74, 72.216,73.71, and Part 21. In particular,10 CFR 50.9 (b) states "Each applicant or licensee shall notify the Commission of information identified by the applicant or licensee as having for the regulated actWity a significant implication for public health and safety or common defense end security." This applies to information which is not already required by other reporting or updating requirements. Notification must be made to the Administrator of the appropriate Regional Office within two working days of identifying the information. Reporting pursuar.t to 15 NUREG-1022, Rev.1

$50.9 is required, not voluntary.N Voluntary reporting, as discussed in the following paragraphs, pertains to information of lesser significance than described in $50.9(b).

The Statement of Considerations for 10 CFR 50.73 states "... licensees are permitted and encouraged to report any event or condition that does not meet the criteria contained in

$50.73(a), if the licensee beheves that the event or condition might be of safety significance or of generic interest or concern. Reporting requirements aside, assurance of safe operation of all plants depends on accurate and complete reporting by each licensee of all events having potential safety significance."m Instructions for completing voluntary '.ERs are discussed in Section 5.1.5 of this report. In addition, voluntary reporting is encouraged under 10 CFR 50.72, as discussed in Section 4.2.2 of this report.

The NRC staff encourages voluntary LERs rather than information letters to report operational events that do not meet the criteria contained in 10 CFR 50.73. The LER format is preferable because it provides for the information needed to support NRC review of the event and -

facilitates adrninistrative processing, including data entry.

2.10 Retraction /Cance'lation of Event Reports Licensees have expressed concerns about the counting of event reports, both ENS notifications and LERs. The NRC staff has :ndicated that its interest is in evaluating the reported information, not in simply counting the number of events reported. While event reports may be formally withdrawn, the staff has often found the information reported useful and has maintained the information on file with the withdrawal notation.

If a licensee so chooses, an ENS notification can be retracted via a follow-up ENS calli LER retractions should be made by letterJThe retractions and cancellations are further discussed in Sectica 4 for ENS notifications and.Section 5 for LERs. Sound, logical bases for the withdrawal should be communicated with the retraction or cancellation. (Example 3 in Section 3.3.1 illustrates a case where there were sound reasons for a retraction. The last event under Example 1 in Section 3.3.2 illustrates a case where the reasons for retraction were not adequate.)

2.11 Time Limits for Reporting Reporting times in 10 CFR 50.72 are hyed to the occurrence of the event or condition, as described below.

W As indicated in the Statement of Considerations for $50.9, "A licensee cannot evade the rule by never ' finding'information to be significant. The fact that e licensee considers information to be significant can be established, for example, by the actions taken by the licensee to evaluate that information." 59 FR 49362, December 31,1987.

A 48 FR 33853, July 26,1983.

NUREG-1022, Rev.1 16

Section 50.72(a)(3) requires ENS notification of the declaration of an Emergency Citt)

" immediately after notification of the appropriate State or local agencies and not later than one-hour after the time the licensee declares one of the Emergency Classes."

Section 50.72(b)(1) requires ENS notification for specific types of events and conditions

" as soon as practical and in all cases, within ene-hour of the occurrence of any of the following:..."

Section 50.72(b)(2) requires ENS notification for specific types of events and conditions

" as soon as practical and in all cases, within four hours of the occurrence of any of the following:... ~

Section 50.73 reqeires submittal of an LER "within 30 days after the discovery" of a reportabla event.

Many reportable events are discovered when they occur. However, if the event is discovered at some later time, the discovery date is when the reportability clock starts under 10 CFR 50.'1.

Discovery date is generally the date when the event was discovered rather than the date when an evaluation of the event is completed. For example, if a technician sees a problem, but a delay occurs before an engineer or supervisor has a chance to review the situation, the discovery date (which starts the 30 day clock) in the date that the technician sees a problem.

In some cases, such as discovery of an existing but previously unrecognized condition, it may be net.essary to undertake an evaivation in order to determine if an event or condition is reportable. If so, the guidance provided in Generic Letter 91 18, "Information to Licensees Regarding two NRC inspection Manual Sections on Resolution of Degraded and Nor conforming Conditions and on Operability," which applies primarily to operability determinations, is appropriate for reportability determinations as well. This guidance indicates th9t, whenever reasonable expectation that the equipment in question is operable no longer exists, or significant doubts begin fo arise, appropriate actions, including reporting, should be taken.

2.12 Outside Design Basis This revision provides new guidance and several examples for this reporting criterion and two related criteria, seriously degraded conctition and unanalyzed condition that seriously compromised plant safety. Furth;,i guidance bey ind that provided in this revision is being deferred pending rulemaking to address issues sucn Os: (1) one-hour reporting for design basis issues, (2) significance testing for reporting design basc issues, and (3) scope of plant design basis. See Section 3.2.4 of this report for further discussu.

17 NUREG-1022, Rev.1 I

9 3 SPECIFIC REPORTING GUIDELINES This section addresses the specific requirements of each part of the rules cited for immediate notification of an event under 10 CFR 50.72 via the ENS and 30-day written reports under 10 CFR 50.73 via LERs. The section is divided into four parts. Section 3.1 gives the general requirements for reporting, Section 3.2 gives the criteria for 1-hour notifications and 30-day reports, Section 3.3 gives the criteria for 4-hour notifications and 30-day reports, and Section 3.4 addresses followup notifications.

The sequential scheme of 10 CFR 50.7' is used, which generally categorizes the times for reporting by the relative importance of the event t condition. Because considerable overlap exists between the various reporting criteria in each rule, the associated requirements for licensee event reporting (10 CFR 50.73) are given coincidentally. Differences in the wording of the comparable parts of the rules are underlined. In severalinstances, the wording of the two rules is the same axcept for verb tense. A discussion of reporting guidelines and examples follow each citation of specific parts of the rules. Brief examples occasionally are given in the discussion for clarification; however, expanded examples for each part of the rules are discussed under " Examples." The descriptions in the expanded examples have been taken from actual operational experience and have been condensed to illustrate specific aspects of reportability.

The reporting requirements in each of the two rules are not mutually exclusive, and many evente and conditions are reportable under more than one criterion. Therefore, it is important to first recognize whether an event or condition is reportable under at least one criterion, and then to identify other applicable criteria. When the report is made to the NRC, applicable criteria should be cited.

i 19 NUREG-1022, Rev.1

4 3.1 Sechon 50.72 and 50.73 General Requirements

)

3.1.1 Immediate Notification Requirements

$50.72(a) General Requirements' 10 CFR 50.73 1

l

"(1) Each nuclear power reactor licensee licensed under

[lf the event or condition l

j

$50.21(b) or $50.22 of this part shall notify the NRC that was the basis for Operations Center via the Emergency Notification System of.

the Emergency Class 4

(i) The declaration of any of the Emergency Classes declaration met one or specified in the licensee's approved Emergency Plan;' or more of the 10 CFR (ii) Of those non Emergency events specified in paragraph 50.73 reporting criteria, j

(b) of this section.

an LER is required.)

l 1

(2) If the Emergency Notification System is inoperative, the licensee shall make the required notifications via commercial 1

telephone service, other dodicated telephone systam, or any other method which will ensure that a report is nade as soon l

as practical to the NRC Operations Ce,ter.8 q

(3) The licensee shall notify the NRC immediately after notification of the appropriate State or local agencies and not 9

later than one hour after the time the licensee declares one of the Emergency Classes.

(4) The licensee shall activate the Emergency Response Data System (ERDS)$ as soon as possible but not later than one hour after declaring an emergency class of alert, site area emergency, or general emergency. The ERDS may also be activated by the licensee during emergency drills o: axercises if (19 licensee's computer system has capability to transmit thc exercise data."

"' Other requirements for immediate notification of the NRC by licensed operating nuclear power reactors are contained elsewhere in this chapter, in particular, $5 20.1906,20.2202, 50.36, and 73.71.

' These Emergency Classes are addressed in Appendix E of this part.

3 Commercial telephone number of the NRC Operations Center is (301) 816-5100."

[ Reserved) 5 Requirements for ERDS are addressed in Appendix E,Section VI."

(Continued on next page)

NUREG-1022, Rev 1 20 t

.__,,-,.__-_m._

_4,

.-...J..-..__,

.,, -. _,.. ~,, _ ~ - -

t i

i l

l i

60.72(a) (Continued) i i

"(5) When making a report under paragraph (a)(3) of this l

section, the licensee shall identify i

. i) The Emergency Class declared; or

(

(ii) Either paragraph (b)(1), "One-Hour Report," or paragraph (b)(2), "Four Hour Report," as the paragraph of this

]

section requiring notification of the Non Emergency Event."

I i

I Discusal0D

.j Appendix E to 10 CFR Part 50, Section IV (C), " Activation of Emergency Organization,"

i

_ establishes four emergency classes for nuclear power plants: Notification of Unusual Event, Alert, Site Area Emergency, and General Emergency. NUREG-0654/ FEMA REP-1, Revision 1,

'" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and l

?

Pseparedness in Support of Nuclear Power Plants" (March 1987), and more recently, l

NUMARC/NESP-007, Revision 2, " Methodology for Development of Emergency Action Levels" (January igg 2), provides the basis for these emergency classes and numerous examples of the events and conditions typical of each emergency class. Licensees use this guidance in.

i

- preparing their emergency plans. Use of these four emergency class terms in the ENS l

notification will help the NRC recognize the significance of an emergency. Time frames

.specified for notification in $50.72(a) use the words "immediately" and "not later than one hour" to ensure the Commission can fulfill its responsibilities during and following the most serious i

events.

Docesionally,1a.lirionoce may discover that an event or condition had existed which met the emergoney plan critetta but that.no emergency had been dealered and the.besie for the emergency close no. longer existe st the time of this discovery.iThie. mey be due to a rapidly

[

concluded event or en oversight in the_ emergency clasemoetion made during the event or it iney,be determined during a~ post event reviewa Frequently; in cases.of this naturstwhich. wore discovered siter the fact, licensees have declared the emergency clees, immediately terminated the emergency close end.then made the approprieto notifloationer-However,- the staff.does not ooneider actual declaration of the emergency cleos to be necoseary in these circumstanose; an ENS notmoetion (or en ENS updele if,the event was previously reported but miscloosilled):

within one hour of the discovery of the undeclared (or.misolossilled) event will provide,an

&* anomative."

l a

9 i

L Notification of the State and local emergency response organizations should be made in accordance with the arrangements made between the licensee and offsite 1

organizatior:3.

21 NUREG-1022, Rev.1

.m..

~_ _ - _ _ _ _.. _ ___

f i

I z

3.1.2 Licensee Event Report System 1

10 CFR 50.72

$60.73(a)(1) 4

[ Bases for ENS notifications "The holder of an operating license for a nuclear power g

(o g., regardless of plant plant (licensee) shall abmit a Licensee Event Repor 3

status), are the same as 10 (LER) for any event of the type described in this pag apS ~

CFR 50.73 where the two within 30 days after the discovery of the event. Uning rules are complementary.)

otherwise specified in thir tection, the licensee shallivpg an event regardless of the plant mode or power level, and

+

regardless of the significance of the structure, system, or component that initiated the event."

I Discussion Unless otherwise specified, this part of the rule requires reporting of an event [ggardless of the plant mode or power level and reaardless of the significance of the structure, system, or component that initiated the event. These considerations also are implicit in 10 CFR 50.72 where the two rules are complementary.

t' l

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l 3.2 One hour ENS Notifications and 30-Day LERs l

1 This section addresses $50.72(b)(1) 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months notificatior,s for non emergency events and the i

associated 10 CFR CO.73 written reports. If not reported as a declaration of an emergency class l'

under $50.72(a), licensees are to notify the NRC as soon as practical and in all cases within 1 3

l-hour of the occurrence of any of the events specified in $50.72(b)(1) and to submit an LER, if

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i specified.

In addition to similar reporting criteria under both 10 CFR 50.72 and 50.73, several i

requirements for only 50.72 notifications or only LERs are included in this section because of the sequential numbering scheme used. For example, operation or a condition prohibited by the plant's technical specifications (TS), as discussed in Section 3.2.2, requires an LER but no ENS notification, while loss of emergency assessment, response or cornmunications capability,

. as discussed in Section 3.2.7, requires an ENS notification but no LER, i

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f 23 NUREG-1022, Rev.1

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3.2.1 Plant Shutdown Required by Technical Specifications

$50.72(b)(1)(1)(A)

$50.73(a)(2)(1)(A)

Licensees shall tegoft "The iQitiation of any Licensees shall submit a Licensee Event nuclear plant shutdown required by the flepoloD "The comoletioa of any nuclear plant's Technical Specificatioris.

plant shutdown required by the plant's Technical Specifications."

If not reported as an emergency under $50.72(a), licensees are required to report the initiation of a plant shutdown required by TS to the NRC via the ENS as soon as practical and in all cases within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of the initiation of a plant shutdown required by TS to the NRC via the ENS.

If the shutdown is completed, licensees are required to submit an LER within 30 days.

DiSGtJSSL00 The 950.72 reporting requirement is intended to capture those events for which TS require the initiation of reactor shutdown to provide the NRC with early warning of safety significant conditions serious enough to warrant that the plant be shut down.

For $50.72 reporting purposes, the phrase " initiation of any nuclear plant shutdown" includes action to start reducing reactor power, i.e., adding negative reactivity to achieve a nuclear plant shutdown required by TS. The " initiation of any nuclear plant shutdown" does not include mode l

changes required by TS if initiated after the plant is already in a shutdown condition.

A reduction in power for some other purpose, not constituting initiation of a shutdown required l

by TS, is not reportable under this criterion.

For $50.73 reporting purposes, the phrase " completion of any nuclear plant shutdown"is defined as the point in time during a TS required shutdown when the plant enters the first shutdown condition required by a limiting condition for operations (LCO) e.g., hot standby l

l

{ Mode 3) for PWRs with the standard technical specifications (STS). For example, if at 0200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months a plant enters an LCO action statement that states, " restore the inoperable channel to operable status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at least Hot Standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ," the plant must be shut dowr. (i e., at least in hot standby) by 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months . An LER is required if the inoperab!e channel is not returned to operable status by 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months and the plant enters hot standby.

An LER is not required if a failure was or could have been corrected before a plant has completed shutdown (as discussed above) and no other criteria in @50.73 apply.

i NUREG 1022, Rev.1 24

Examoles (1)

Initiation of a TS Required Plant Shutdown While operating at 100-percent power, one of the battery chargers, which feeds a 125 3

Vdc vital bus, failed during a surveillance test. The battery charger was declared inoperable, placing the plant in a 2-hour LCO to return the battery charger to an operable status or commence a TS required plant shutdown. Licensee personnel started reducing reactor power 'o achieve a nuclear plant shutdown required by a TS 4

l when they overe unable to complete repairs to the inoporable battery charger in the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allowed. The cause of the battery charger failure was subsequently identified and repaired. Upon completion of surveillance. testing, the battery charger was returned to service and the TS required plant shutdown was stopped at 96 percent power.

The licensee made an ENS notification because of the initiation of a TS required plant j

shutdown An LER was not submitted under this criterion since the failed battery charger was corrected before the plant completed shutdown.

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(2) initiation and Compielion of a TG Required Plant Shutdown During startup of a PWR plant with reactor power in the intermediate range, two of the four reactor coolant pumps (RCPs) tripped when the station power transformer supplying power, deenergized. With less than four RCPs operating, the plant entered a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months LCO to be in hot standby. Control rods were manually inserted to place the plant l

in a shutdown condition.

The licensee made an ENS notification because of the initiation of a TS required plant i

shutdown. An LER was submitted within 30 days because of the completion of the TS-required plant shutdown.

(3)

Failure that was or could have been corrected before a plant has completed shut down.

o Question:

What about the situation where you have seven days to fix a component or be shut down, but the plant must be shut down to fix the component? Assume the plant shuts down, the component is fixed, and the plant returns to power prior to the end of the seven day period, is that situation reportable?

Answer:

No. If the shutdown was not required by the Technical Specifications, it need not be reported. However, other criteria in 50.73 may apply and may require that the event be reported.

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Question:

Suppose that there are seven days to fix a problem and it is likely the problem can be fixed during this time period. However, the plant management elects to shut down and fix this problem and other problems. It an LER required?

Answer:

Some judgment is required. An LER is not required if the situation could have been corrected before the plant was required to be shut down, and no other enteria in 50.73 apply. The shut down is reportable, however, if the situation could not have been corrected before the plant was required to be shut down, or if other criteria of 50.73 apply.

NUREG-1022, Rev 1 26

3.2.2 Technical Specification Prohibited Operation or Condition 10 CFR 50.72 650.73(a)(2)(1)(B)

[There is no corresponding Part 50.72 requirement.

Licensees shall report: "any However, for certain operations or conditions operation or condition prohibited prohibited by a plant's TS, other reporbng by the plant's Technical requirements may apply, such as 50.72(b)(1)(ii) and Specifications."

(b)(2)(iii); 50.36(c)(1) r.nd (2); 20.2202; and 20.2203.]

Licensees are required to submit an LER within 30 days for any operation or condition prohibited by technical specifications.

Dis.cussion Section 50.73(a)(2)(1)(B) requires any operation or condition that is prohibited by the plant's TS to be reported in an LER. The five specific TS categories defined in 10 CFR 50.36(c),

" Technical Specifications," are discussed below. In addition, based on past experience, guidelines are provided for reporting entry into TS 3.0.3 [ISTS W Limiting Condition for Operation (LCO) 3.0.3); missed or deficient tests required by the American Society of Mechanical Engineers (ASME)Section XI, inservice Testing (IST) and inservice Inspection (ISI), and by STS 4.0.5, or equivalent; and other operations or conditions prohibited by TS, such as fire protection.

The LER rule does not address violations of license conditions contained in documents other than the TS. Such notifications are reportable as specified in a plant's license or other applicable documents.

(1)

Safety Limits and Limiting Safety System Settings Section 50.36(c)(1) outlines the reporting requirements in TS when nuclear reactor safety limits or limiting safety system settings are exceeded and identifies that such reports are to be made under 50.72 and 50.73.

W To be consistent with the improved Standard Technical Specifications (ISTS) discussed in the NUREG-1430 through NUREG 1434 (e.g., NUREG-1431, Vol.1, Standard Technical Specifications - Westinghouse Plants, September 1992) references to appropriate sections in these ISTS have been included throughout this section of NUREG-1022. The designation used here for references to such sections is "lSTS" followed by the appropriate section number.

27 NUREG 1022, Rev.1

(2)

Limiting Conditions for Operation Section 50.36(c)(2) outlines LCOs in TS. Certain TS contain LCO statements that include action statements (required actions and associated completion time in ISTS) to provide constraints on the length of time components or systems may remain inoperable or out of service before the plant must shut down or other compensatory measures must be taken. Such time constraints are based on the safety significance of the component or system being removed from service.

An LER is required if the conditions of an LCO are not met, e.g., by exceeding action statement constraints (not meeting required actions and associated completion times in ISTS).

The LCO allows a plant a specific time interval referred to as the allowed outage time (or completion time in ISTS) to accomplish corrective actions (e.g., restoration of equipment, testing of other equipment, and/or an orderly shutdown to either the hot or cold-shatdown mode or operating condition).

If a condition existed for a time longer than permitted by the TS (i.e., greater than the allowed outage time (or completion time in ISTS)] it must be reported even if the condition was not discovered until after the allowable time had elapsed and the condition was rectified immediately upon discovery. This guidance is consistent with that previously given. (For the purpose of this discussion, it is assumed that there was firm evidence that a condition prohibited by TS existed before discovery, for a time longer than permitted by TS.)

(3)

TS Surveillance Requirements Section 50.36(c)(3) outlines surveillance requirements in TS which assure (1) necessary quality of systems and components, (2) operation within safety limits, and (3) that the limiting conditions for operation will be met. For the purpose of evaluating the reportability of discrepancies found during TS surveillance tests, an operation or condition prohibited by the TS existed and is reportable if the time of equipment inoperability exceeded the LCO allowed outage time (or completion time for restoration of equipment in ISTS). It should be assumed that the discrepancy occurred at the time of its discovery unless there is firm evidence, based on a review of relevant information (e.g., the equipment history and cause of failure) to believe that the discrepancy existed previously. As discussed in Example 5, evaluation of multiple similar failures may indicate that a condition has persisted for some time.

Missed surveillance tests are reportable when the surveillance interval plus allowed surveillance interval extension, e g., STS section 4 0.2 (or ISTS SR 3.0.2), plus ths LCO action statement time is exceeded.* This means that a condition prohibited by TS W The Statement of Considerations for the final rule (48 FR 33855, July 28,1983, Second column) states, in part, ", if a condition that was prohibited by the Technical NUREG 1022, Rev.1 28

~-.

existed for a period of time longer than allowed by TS, The event is reportable even though the surveillance is subsequently satisfactorily performed.W Some plants have TS which allow a delay of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in declaring an LCO or TS requirements not met if it is found that a surveillance was not performed within its specified frequency or interval. However, failure to perform a surveillance within its frequency or interval is still reportable. The additional delay in declaring the LCO not met does not change the fact that the condition existed longer than allowed by TS, The delay merely specifies appropriate r6 medial action, (4)

Design Features Section 50.36(c)(4) indicates that design features to be included in TS are those j

features of the facility such as materials of construction or geometric arrangements which, if altered or modified, would have a significant effect on safety and are not covered by items (1) through (3) above.

Reportability requirements related to design features are included in other sections of 10 CFR 50.72 and 50.73.

(5)

TS Administrative Requirements, including Radiological Controls, Required by Section 6 of the STS, or Equivalent Section 6 of the STS (Section 5 of ISTS), or its equivalent, has a number of administrative requirements such as organizational structure, the required number of personnel on shift, the maximum hours of work permitted during a specific interval of time, and the requirement to have, maintain, and implement certain specified procedures.

reitur; t; mn; ;uch ;dmbb;;;;;;; ;;;..mm:nt b Fehi:Md by it; TS. 7.hth;r it b rep;Obb ;; en LEn ;% pad; upn wM;her ?; ;;; A in ; wad;;ba ;;;;;;d by the LCC rub. if the vbb bn c' th; edmbi;. ;.;; requ;;;;nent ;' TS i::M: in ep;;;ba; Feh1;%d by TS,; hen it b i;p;; ebb, Violation of an administrative TS in and of itself does not necessarily constitute a reportable condition (" operation or condition prohibited by the plant's TS"); This Specifications existed for a period of time longer than that permitted by the Technical Specifications, it must be reported even if the condition was not discovered until after the allowable time had elapsed and the condition was rectified immediately after discovery."

W This guidance is only intended to define when the matter becomes reportable under this specific reporting criterion (" operation or condition prohibited by the plant's TS"). It is not intended to define when a TS violation occurs, when a system must actually be declared inoperable, when the surveillance must be completed, or when the plant must be shutdown.

These matters are discussed further in GL 87-09, GL 91-18, TS 4.0.2, and ISTS SR 3.0.3.

29 NUREG-1022, Rev.1

reporting requirement deals with matters affecting plant operation more substantially and more directly than t'atters that are mainly administrative?' Failure to rneet j

administrative TS requipments is reportable only ifit results in violations of equipment operability requirenients, or had a similar detrimental effect on a licensee's ability to safely operate the plant.

For example, operation with less than the required number of people on shift would constitute operation prohibited by the TS. However, a change in the plant's organizational structure that has not yet been approved as a Technical Specification change would not.

An administrative proce> dure violation or failure to implement a procedure, such as failure to lock a high radiation area door, that does not have a direct impact on the safe rSeration of the plant, isgenerally not reportable under this criterion.

Radiological conditions and events that are reportable are defined in 10 CFR 20.2202 and 20.2203. Redundant reporting is not required.

(6)

Entry into STS 3.0.3 STS 3.0.3 (ISTS LCO 3.0.3), or its equivalent, establishes requirements for actions when an LCO is not met and no action statement is provided. Entry into STS 3.0.3 is considered to be the action taken, as required, when operations or conditions required by TS LCO action statements (ISTS required actions and associated completion times) are not met. Thus, entry into STS 3.0.3 (ISTS LCO 3.0.3) for any reason or justification is reportable.

(7)

Missed Tests Required by ASME Section XI IST and ISI and by STS 4.0.5, or Equivalent Sections 50.55a(g) and 50.55a(f) require the implementation of ISI and IST programs in accordance with the applicable edition of the ASME Code for those pumps and valves whose function is required for safety. STS Section 4.0.5 (or an equivalent) covers these wsting requirements. (Generally, there is no comparable ISTS section.) Missed IST/ISI/ASME tests are reportable when the test interval plus any allowable extension plus the LCO action time has been exceeded.

m The proposed rule would have required reporting when "a TS action statement is rnt met." The wording of the final rule requires reporting "Any operation or condition prohibited by the plant's Technical Specifications." The Statement of Considerations for the final rule indicates that this chtnge was made to accommodate plants that did not have requirements specifically defined as action statements (48 FR 33855, July 26,1983).

NUREG-1022, Rev.1 30

(8)

Fire Protection Systems When Required by TS When operability requirements for fire protection systems are specified in TS they are within the scope of this reporting criterion.

Examoles (1)

LCO Exceeded A licensee found a standby component with a 7-day LCO allowed outage time and associated 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months shutdown action statement to be inoperable during a 30-day surveillance test. (This is equivalent to a 7-day restoration completion time and an 8-hour action completion time in ISTS.) Subsequent review indicated that the component was assembled improperly during maintenance conducted 30 days previously and the post-maintenance test was not adequate to identify the error. Thus, there was firm evidence that the standby component had been inoperable for the entire 30 da/s.

An LER was required because the 7-day LCO allov'ed outage time and the shutdown action statement time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months were exceeded. Had the inoperability been identified and corrected within the 7-day LCO allowed outage time plus the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months shutdown action statement, the event would not be reportable.

(2)

Missed Surveillance Tests A licensee, with the plant in Mode 5 following a 10-month refueling outage, determined that certain monthly TS surveillance tests, which were required in be performed regardless of plant mode, had not been performed as required during the outage. The STS 4.0.2 (equivalent to ISTS SR 3.0.2) extension was also exceeded. The surveillance tests were immediately performed. An LER is required because the time interval, including extensions permitted by TS, exceeded the TS surveillance interval plus the LCO action statement times (equivalent to ISTS completion times).

(3)

Entering STS 3.0.3 With essential water chillers, (A) and (B) out of service, the only remaining operable chiller (A/B) tripped. This condition caused the plant to enter STS 3.0.3 (equivalent to ISTS LCO 3.0.3) for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months until chiller (A) was restored to service and the temperature was restored to within TS limits. An LER is required for this event because STS 3.0.3 was entered.

(4)

Missed Tests Required by ASME Section XI IST ard ISI, and by STS 4.0.5, or Equivalent Examples of potentially rmtable conditions are failures to perform required activities within specified times for ase components governed by TS. Such activities include i

stroke testing valves, teen J valves in the position required for the performance of their i

safety function, verifying motor-operated valve stroke times for both (open and closed) 31 NUREG-1022, Rev. i

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directions, using the proper test pressures to properly classify and test active valves and I

to increase test frequency subsequent to obtaining test results that were below certain i

threshold values. A missed test is reportable when_ the test interval plus any allowable I

extension plus the LCO action time is exceeded.

(5)

Multiple Test Failures An example of multiple test failures involves the sequential testing of safety valves.

Sometimes multiple valves are found to lift with setpoints outside of TS limits.

As discussed above, discrepancies found in TS surveillance tests should be assumed tr.,

occur at the time of the test unless there is firm evidence, based on a review of relevant information (e.g., the equipment history and the cause of failure) to believe that the discrepancy occurred earlier. However, the existence of similar discrepancies in multiple valves is an indication that the discrepancies arose over a period of time.

Therefore, the condition existed during plant operation and the event is reportable under

$50.73(a)(2)(i)(B)"Any operation or condition prohibited by the plant's Technical Specifications."

if the discrepancies are large enough that multiple valves are inoperable the event may also be reportable under $50.73(a)(2)(vii) "Any event where a single cause or condition caused at least one independent train or channel to become inoperable in multiple systems or two independent trains or channels to become inoperable in a single system...."

NUREG-1022, Rev.1 '

32

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3.2.3 Technical Specification Deviation per $50.54(x) 650.72(b)(1)(1)(B)

$50.73(a)(2)(1)(C)

Licensees shall report: "Any deviation from Licensees shall report: "Any deviation from the plant's Technical Specifications the plant's Technical Specifications authorized pursuant to $50.54(x) of this authorized pursuant to $50.54(x) of this part."

part."

If not reported as an emergency under $50.72(a), licensees are required to report any such deviation to the NRC via the ENS as soon as practical and in all cases within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Licensees are required to submit an LER within 30 days.

DiscussioD 10 CFR 50.54(x) generally permits licensees to take reasonable action in an emergency even though the action departs from the license conditions or plant technical specifications if (1) the action is immediately needed to protect the public health and safety, including plant personnel, and (2) no action consistent with the license coriditions and technical specifications is immediately apparent that can provide adequate or equivalent protection. Deviations authorized pursuant to 10 CFR 50.54(x) are reportable under this criterion.

Examole With the plant at 100-percent power, the upper containment airlock inner door was opened to allow a technician to exit from the containment while the upper airlock outer door was inoperable, resulting in the loss of containment integrity. The upper airlock door was inoperable pending retests following seal replacement. The technician was inside containment when the lower airlock failed, requiring the technician to exit through the upper door.

The licensee decided to exercise the option allowed for under 10 CFR 50.54(x) and open the upper containment airlock inner door. In this instance, immediate action was considered necessary to protect the safety of the technician. The upper airlock was not scheduled to be returned to operability for another 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months and the time to repair the lower airlock door was unknown. When the action was completed the control room operators notified the NRC Operations Center, in accordance with the reporting requirements of 10 CFR 50.72, that they had exercised 10 CFR 50.54(x).

Subsequently, an LER was submitted in accordance with 10 CFR 50.73(a)(2)(i) {use of 10 CFR 50.54(x)) as well as 10 CFR 50.73(a)(2)(v) { event or condition that alone could prevent...}.

33 NUREG-1022, Rev.1

3.2.4 Operating Plant Found in Degraded or Unanalyzed Condition

$50.72(b)(1)(ll) 650.73(a)(2)(li)

Licensees shall report: "Any event or Licensees shall report: "Any event or condition durina ooeration that results in the condition that resultad in the condition of the condition of the nuclear power plant, nuclear power plant, including its principal including its principet safety barriers, being safety barriers, being seriously degraded; or seriously degraded; or results in the nuclear that resulted in the nuclear power plant power plant being.

being:

(A)In an unanalyzed condition that (A)In an unanalyzed condition that significantly compromises plant safety; significantly compromised plant safety; (B) In a condition that is outside the design (B) In a condition that was outside the basis of the plant; or design basis of the plant; or (C)In a condition not covered by the (C)In a condition not covered by the plant's operating and emergency planfs operating and emergency procedures,"

procedures."

If not reported as an emergency under $50.72la), licensees are required to report operation under such a condition to the NRC via the ENS as soon as practical and in all cases within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Licensees are required to submit an LER within 30 days.

Discussion Reporting at the component, system, and structure level is required under 10 CFR 50.72(b)(1)(i!) and 50.73(a)(2)(ii)if the event or condition resulted in the plant being seriously degraded, in an unanalyzed condition that significantly compromises plant safety, outside the plant design basis, or in a condition not covered by the plant's procedures, as described in the rule.

The discussions below provide further guidance on reportability under these criteria.

(1)

The condition of the nuclear oower olant. includina its orincioal safety barriers. beina seriousiv dearaded.

As indicated in the Statements of Considerations, this paragraph includes material (e.g.,

metallurgical or chemical) problems that cause abnormal degradation of the principal safety barriers (i.e., the fuel cladding, reactor coolant system pressure boundary, or the containment). Examples of this type of situation include:

(a)

Fuel cladding failures in the reactor, or in the storage pool, that exceed expected values, or that are unique or widespread, or that are caused by unexpected -

factors, and would involve a release of significant quantities of fission products, NUREG 1022, Rev.1 34

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l (b)

Cracks and breaks in the piping or reactor vessel (steel or prestressed concrete) or major components in the primary coolant circuit that have safety relevance (steam generators, reactor coolant pumps, valves, etc).

t j

(c)

Significant welding or material defects in the primary coolant sy., tem.

f 1

(d)

Serious temperature or pressure transients.

(e)

Loss of relief and/or safety valve functions during operation.

(f)

Loss of containment function or integrity including:

(i)

Containment leakage rates exceeding the authorized limits.

j (ii)

Loss of containment isolation valve function during tests or operation.

(iii)

Loss of main steam isolation valve function during test or operation, or l

1 i

I (iv)

Loss of containment cooling capability.

Examples of events that the _ staff would consider reportable as significant reactor i

ooolant system welding or material defects include items which cannot be found 2

soceptable under ASME Section XI,- lWB-3600,," Analytical Evaluation of Flaws" or l

ASME Section XI; Tcble IWB 34101, " Acceptance Standards."

i Examples.of events that t5e staff would conCder reportable as serious temperature or pressure transients. include low temperature over pressure transients where the pressure-temperature relationship violates pressure-temperature limits derived from Appendix G to 10 CFR Part 50 (e.g, TS pressure-temperature curves),

t Examples of events the staff would consider. reportable as containment leakage rates exceeding authorized limits include containment leak rate tests where the total conteinment as-found, minimum-pathway leak rate exceeds the LCO in the facility's TS,")(')

1 i

?

W The LCO typically employs La, which is defined in Appendix J to 10 CFR Part 50 as the maximum allowable containment leak rate at pressure Pa, the calculated peak containment intemal pressure related to the design basis accident. Minimum-pathway leak rate means the minimum leak rate that can be attributed to a penetration leakage path; for example, the smaller i

of either the inboard or outboard valve's individual leak rates.

1 m

For such a condition, an LER is generally required under 10 CFR 50.73(a)(2)(ii), if the condition existed during operation, an ENS notification would also be required by

$50.72(b)(1)(ii)if found during operation or by $50.72(b)(2)(i)if found while shutdown.

35 NUREG 1022 Rav,1

i G)

The nuclear Dc=r olant beina in an unanalvzed condition that sianificantiv comDromises Diant safelV.

t As indicated in the Statements of Consideration:

'The Commission recognizes that the licensee may use engineering judgment and experience to determine v.hether an unanalyzed condition existed. It is not intended that thir 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 Lituation 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 corsoonents or if they significantly compromise plant safety,'49

'When applying engineering judgment, and there is a deJbt regarding whether to report or not, the Commission's policy is that licensees sbould make the report.'4")

"For example, small voide in systems designed to remove r eat from the reactor core which have been previously shown through analysis n >t to be safety significant need not be reported. However, the accumulati.'n of voids that could inhibit the ability to adequately remove heat from the react.r core, particularly under natural circulation conditions, would constitute an ur analyzed condition and would be reportable 'im "In addition, voiding in instrument lines that results in an erroneous indication causing the operator to rnisunderstand the true condition of the plant is also an unanalyzed condition and should be reported '4"3 Q)

The nuclear oower olant being in a condition that is outside the desian basis of the olant.

i As indicated in 10 CFR 50.2, " Design bases means that information which identifies the l

specific functions to be performed by a structure, system, or component of a facility, and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived.om generally accepted

' state of the art' practices for achieving functional goals, or (2) requirements derived

(*

48 FR 39042, August 29,1983 and 48 FR 33856, July 26,1983.

l

(")

48 FR 39042, August 29,1983, ori 48 FR 39042, August 29,1983 and 48 FR 33856, July 26,1983.

P83 48 FR 39042, August 29,1983 and 48 FR 33856, July 26,1983.

NUREG-1022, Rev.1 36

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from analysis (based on calculation and/or experiments) of tha effects of a postulated accident for which a structure, system, or component must meet its functional goals."

l (Emphasis added.)

1 Esemples of evenes or eenellons the soon considers reportable include errors in the I

salues assign, such se escovery that en ECCS design does not most the eingle failure ornertenc They else. inchese hardware problems such as discovery that high energy line j

lueek restruires are. net _ instened_,

4 i

With regard to ECCS calculations, detailed reporting criteria are given in 10 CFR 50.48(a). That rule provides that a change or error correction that results in calculated ECCS performance that does not meet the acceptance criteria { peak cladding j

temperature, cladding oxidation, etc.} is a reportable event as described in 10 CFR 50.55(e),50.72 and 50.73. Lesser changes or error corrections are the subject of other, l

sepa,*ste reports.

i Vielellen'of Are protection commitments regarding safe shutdown capeldtity may indioste i

est the pont is outside of its.doelen beels. For example, if fire barriors are found to be fniesingi auch tiet the required degree of esperation for. redundant safe shutdown traits is lesidng; Wie plant would be outside of.the design basis with respect to Appendix R to L

to CPR Port 8G7:9n the es%hendi if a are wrapito which the licensee has commened, i

is adeseng som.e esse shutdown train but another esse shutdown train is evaliable in a eneront to.erseiprotected such that the required esperation for, esse shutdown trains is semi providentine plant would not be outside of its design beeis with _ respect to

$ppendk R[*I Another esemple.of an event or oordtion that the.etaff considers reportable is +==y met one gain et e seguired two wein espety system has been incepobie of performing its design funellen (Intemled esisty function) for en exteded portod of time during eperation2 Per esemple,.in a two4 rein ECCS system l one train might be found with. a doelen gew or wept e osmponent that would never have functioned boosune it was inetsted insenectly and.e test that would reveel the problem was not performed, such that the tein wee incepoble of performing its_doelen function.;This would be considered outehip the_ design heels because the system did not have suitable redundancy?H l

" *)

The design basis with respect to Appendix R for protection of safe shutdown capability is essentially the sarne as the required protection features. This is discussed in the i

J Statement of Considerations for Appendix R, Federal Register, November ig, 1980 (45 FR 76606). In particular, it is stated that "Because it is not possible to predict the specific conditions under which fires may occur and propagate, the design basis protective features a?

specified rather than the design basis fire."

09 A minimum design feature is suitable redundancy meeting the single-failure l

criterion as indicated in: (1) 10 CFR Part 50, Appendix A, Introduction and 10 CFR 50, Appendix A, Criterion 35; (2) 10 CFR 50, Appendix K, item 1.D.1; AND (3) FSAR commitments.

L 37 NUREG-1022, Rev.1 l

lt should be noted that these discussions concern events or conditions that actually place the plant outside its design basis. They are not intended to capture minor problems such as; (1) cases of administrative Inoperability, where a component is declared inoperable because a surveillance test is overdue but the equipment is actually capable of performing its design function, or (2) cases where the LCO allowed outage time is exceeded by a modest amount (e.g., less than 25 percent). Such conditions may, however, be reportable as conditions prohibited by the Technical Specifications,10 CFR 50.73(a)(2)(l)(B).

U2

.The nuclear oower olant beina in a condition not covered by the olant's ooeratina and Om2[gency oro.cedutos.

This enterion points to events where the plant is in a condition outside the coverage of its operating and emergency procedures! A straightforward example of this type of event was the accident at Three Mile island, Examoles (1)

Design Problem (ECCS Single Failure Vulnerability)

A minimum design feature for ECCS is suitable redundancy meeting the single failure criterion. Sources include: (1) 10 CFR Part 50, Appendix A, Introduction and 10 CFR 50, Appendix A, Criterion 35; (2) 10 CFR 50, Appendix K, item 1.D.1; and (3) FSAR commitments. During an engineering review following an event, it was found that a coil shorting in one of several supervisory relays, in conjunction with an accident, could lead to a premature recirculation actuation signal. This could result in loss of water to the ECCS pumps due to realignment of suction to the containment sump. It was also found that such coil shorting could cause closure of pump recirculation isolation valves, potentially dead heading and possibly damaging the HPSI pumps.

The licensee determined that each of these concerns represented a condition outside of the design bases. When each determination was made, an ENS notification was made and immediate actions were taken to fix the single failure problem. Subsequently, an LER was submitted.

The event is reportable because the ECCS failed to meet its design bases.

(2)

Design / Hardware Problem (Turbine Missile Protection)

The original design criteria, as stated in the UFSAR, required that ESFs be protected from turbine generated missiles by means of shielding or separation. As a result of a service water upgrade project it was found that portions of the low pressure service water system (LPSW) did not meet the plant's separation criteria for high trajectory turbine missiles. The licensee provided an ENS notification under 10 CFR 50.72(b)(1)(ii)(B) and submitted an LER under 10 CFR 50.73(a)(2)(ii)(B), outside design basis.

NUREG-1022, Rev.1 38

The corrective action included submitting a UFSAR amendment, which was approved by the NRC staff, to allow using current NRC and industry guidance. When applying this guidance, the LPSW piping in question provides an acceptably low probability target.

This event is reportable because the turbine missilu protection did not meet the design basis as stated in the FSAR.

(3)

ECCS Analysis The large break LOCA analysis, as documented in the FSAR, assumed that high and low head safety injection systems can deliver full flow in 5 and 10 seconds, respectively.

A new analysis was performed, which accounted conservatively for (1) Si signal processing, (2) sequencer delay time uncertainty, and (3) increased time for pump acceleration to full speed due to degraded voltage. This indicated that it could take as much as 8 and 24 seconds, respectively, for the high and low head safety injection systems to deliver full flow.

As a result of the new analysis, calculated peak clad temperature was increased by about 44F. However, peak clad temperature remained below 2200F and other ECCS acceptance criteria continued to be met as well. Although licensee reported the event as outside design bases, staff does not consider the event reportable under that criterion because the provisions of $50.46(a) apply. Under those provisions, the events reportt.ble purst' ant to $50.72 and 650.73 are those where the ECCS acceptance criteria are exceeded.

The event is not reportable because the provisions of $50.46(a) apply and the ECCS acceptance criteria were not exceeded.

(4)

Fire Protection (Separation of Safe Shutdown Trains)

The design for a fire area had been approved on the basis of several specific features including: automatic sprinklers; remote annunciation; and circuit separation via 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months rated fire barriers for redundant safe shutdown circuits. During a design basis review it was found that redundant diesel generator field circuits, located in a common fire area, were not protected or separated by 2-hour rated fire barriers.

An ENS notification was made under 10 CFR 50.72(b)(1)(ii)(B), outside design basis, and subsequently an LER was submitted under 10 CFR 50.73(a)(2)(ii)(B), outside design basis.

The condition was reportable under this criterion because the required design basis protective features for safe shutdown trains, as described in 10 CFR 50, Appendix R i

and the FSAR, were lacking.

l 39 NUREG-1022, Rev.1

(5)

Hardware Problem (Suitable Redundancy and Seismic Qualification)

During an NRC evaluation, it was found that an exciter panel for onc diesel generator had lacked appropriate seismic restraints since the plant was constructed. The Ucensee J

did not initially believe the condition was reportable under 10 CFR 50.72(b)(1)(ii)(B) and 10 CFR 50.73(a)(2)(ii)(B), outside the design basis. However, the staff determined that the condition was reportable under this cnterion because the onsite power system lacked suitable redundancy (seismically qualified) as described in GDC 2, GDC 17 and the SARf*)

j i

The single failure criterion is discussed in 10 CFR 50 Appendix A, Criterion 17 -

D'l Electric Power Systems and the seismic design bases are discussed in 10 CFR 50, Appendix A, Criterion 2 - Design Bases for Protection Against Natural Phenomersa, as well as in the FSAR.

f NUREG-1022, Rev.1 40

3.2.5 External Threat to Plant Safety NA

$50.72(b)(1)(lii) 650.73(a)(2)(lii)

Licensee shall report: "Any natural Licensee shall report: "Any natural phenomenon or other external condition that phenomenon or other external condition that posen an actual threat to the safety of the posed an actual threat to the safety of the nuclear power plant or significantly hampera nuclear power plant or significantly site personnelin the performance of duties hampered site personnel in the performance necessary for the safe operation of the of duties necessary for the safe operation of plant."

the nuclear oower plant."

If not rept

' as an emergency under 950.72(a), licensees are required to report any natural phenomenu.. or other external condition that poses an actual threat to the safety of the nuclear power plant or significantly hampers site personnelin the performance of duties necessary for the safe operation of the plant to the NRC via the ENS as soon as practical and in all cases within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Subsequent evaluation may indicate that the phenomenon did not pose an actual threat or significantly hamper site personnel. If so, an LER is not required and the ENS notification may be retracted. Otherwise, licensees are required to submit an LER within 30 days.

Qjscussion These criteria apply only to acts of nature (e g., tornadoes, earthquakes, fires, lightning, hurricanes, floods) and external hazards (i.e., industrial or transportation accidents).

References to acts of sabotage are cove 9d by 10 CFR 73.71. Actual threats or significant hampering from internal hazards are cc < ered by separate criteria in $50.72(b)(1)(vi) and 550.73(a)(2)(x), as dis:ussed in Sectior. 3.2.8 of this report.

For ENS reporting, the phrase " actual threa-

, aty of the nuclear power plant"is one reporting trigger. This covers those events involving an actual threat to the plant from an external condition or natural phenomenon where the threat or damage challenges the ability of the plant to continue to operate in a safe manner (including the orderly shutdown and maintenance of shutdown conditions).

The licensee should decide if a phenomenon or condition actually threatens the plant. For example, a minor brush fire in a remote area of the site that is quickly controlled by fire fighting personnel end, as a result, did not present a threat to the plant should r.ot be reported.

However, a major forest fire, large-scale flood, or major earthquake that presents a clear threat to the plant should be reported. As another example, an industrial or transportation accident which occurs near the site, creating a plant safety concern, should be reported.

The licensee must use engineering judgment to determine if there was an actual threat. For example, with regard to tornadoes the decision would be based on such factors as the size of 41 NUREG-1022 Rev.1 2

the tornado, and its location and path. There are no prescribed limits. In general, situations involving only monitoring by the plant's staff are not reportable, but if preventive actions are taken or if there are serious concems, then the situation should be carefully reviewed for reportabihty.

Responsive actions, by themselves, do not necessarily indicate actual threats.' Those which are purely precautionary, such as placement of sandbags, even though flood levels are not expected to be high enough to require sandbags, do not trigger reportir$

Some natural phenomena such PS! XXis may be accurately predicted, if there is a credible predlction of a flood that would chat,enge the ability of the plant to continue to operate safely, the threat is reportable as on actual threat via ENS as soon as practical and in all cases within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

in most cases, events such as earthquakes, approaching hurricanes or tornado warnings result in ENS notification because there is a declaration of an emergency class, which is reportable under @50.72(a)(1)(i) as discussed in Section 3.1.1 of this report, rather than because the event is considered an actual threat. Usually, with the passage of time,it is apparent that an actual threat did not occur and, thus, no LER is submitted (see Example 1). In some cases, with the passage of time, it is judged that an actual threat did occur and, thus, an LER is submitted (see Example 2).

Section 3.2.8 of this report discusses the meaning of the phrase "significantly hampers site personnelin the performance of duties necessary for the safe operation of the plant,"in the context of intemal threats. A natural phenomenon or external condition, may also significantly hamper personnel. If so, it is reportable under this enterion.

If a snowstorm, hurricane or similar event significantly hampers personnel in the conduct of activities necessary for the safe operation of the plant, the event is reportable via the ENS as soon as practical and in all cases within i hour, in the case of snow, the licensee must use judgment based on the amount of snow, the extent to which personnel were hampered, the extent to which additional assistance could have been available in an emergency, the length of time the condition existed, etc. For example, if snow prevented shift relief for several hours, the situation would be reportable if the delay were such that site personnel were significantly hampered in the performance of duties necessary for safe operation. For example, shift personnel might exceed normal shift overtime limits, become excessively fatigued, or find it necessary to operate with fewer than the required number of watchstanders in order to allow some to rest.

Examoles (1)

Earthquake beismic alarms were received in the Unit 1 control room of a Southern California plant.

deismic monitors were not tripped in Units 2 or 3. The earthquake was readily felt on site. Seismic instrumentation measured less than 0.02g lateral acceleration.

NUREG-1022, Rev.1 42

=

The licensee classified this as an Unusual Event in accordance with the emergency plan and notified the NRC via ENS per $50.72(a)(1)(i) within 30 minutes of the earthquake.

The licensee tarminated the event after walkdowns of the plant were satisfactorily completed and made an ENS update call. No LER was submitted because the event was not considered to be an actual threat.

(2)

Hurricane A licensee in southern Florida declared an Unusual Event after a hurricane warning was issued by the National Hurricant Center. The hurricane was predicted to reach the site in approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . As part of the licensee's severe weather preparations both operating units were taken to hot shutdown before the hurricane's predicted arrival.

Offsite power to both units was lost. As the hurricane approached, wind velocity on rite was measured in excess of 140 mph. All personnel were withdrawn to protected safety-related structures. Extensive damage occurred on site. The Unusual Event was upgraded to an Alert when the pressurized fire header was lost because of storm-related damage to the fire protection system water supply piping and electric pump. All safety related equipment functioned as designed before, during, and after the storm with the exception of two minor emergency diesel generator anomalies. The licensee downgraded the Alert to an Unusual Event once offsite power was restored and a damage assessment completed.

An ENS notification was required because the licensee declared an emergency class.

The licensee submitted an LER within 30 days of the hurricane, based on the occurrence of a natural phenomenon that posed an actual threat and several other reportbg criteria as well.

(3)

Fire Vrth the unit at 1^ -percent power, the control room was notified that a forest fire was a

burning west of the plant close to the 230-kV distribution lines. Approximately 15 minutes later, voltage fluctuations were observed and then a full reactor scram occurred.

The licensee determined that the offsite distribution breakers had tripped on fault, apparently from heavy smoke and heat in the vicinity of the offsite 230 kV line insulators. The other source of offsite power, i.e., the 34.5-kV lines supplying the startup transformers, was also lost. Both station emergency diesel generators received a fast start signal and load sequenced as designed. Five minutes later, affsite power was available through the startup transformer to the non-safety-related 4160-v buses, but the licensee decided to maintain the vital buses on their emergency power source until the reliability of offsite power could be assured. The fire continued to burn and, although no plant structures or equipment were directly affected, the fire did approach within 70 feet of the fire pump house.

The licensee entered the emergency plan, declaring an Unusual Event based on high drywell temperature ar d an Alert based on the potential of the forest fire to further affect the plant. The licensee submitted an LER within 30 days of the fire, based on the 43 NUREG-1022, Rev.1

occurrence of natural phenomenon that posed an actual threat and several other reporting criteria as well.

NUREG-1022, Rev.1 44

3.2.6 ECCS Discharge into the Reactor Coolant System (50.72(b)(1)(iv) 10 CFR 50.73 Licensees shall report: "Any event that (ECCS discharge is a subset of results or should have resulted in

$50.73(a)(2)(iv), actuation of an engineered Emergency Core Cooling System (ECCS) safety feature (ESF), as discussed in discharge into the reactor coolant system as Section 3.3.2. Therefore, an LER is a result of a valid signal."

required.]

If not reported er an emergency under $50.72(a), licensees are required to notify the NRC via the ENS when a discharge of the ECCS into the RCS occurred or should have occurred as a result of a valid signal as soon as practical and in all cases within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

f l

DiscussiOD Experience with ENS notifications has shown that events involving ECCS discharge to the vessel are generally more serious than ESF actuations without discharge to the vessel. On the basis of this experience, the Commission has made this reporting enterion a 1-hour report.

Those events that resu!!in either automatic or manual actuation of the ECCS or would have resulted in activation of the ECCS if some component had not failed or an operator action had.

not been taken are reportable. For example,if a valid ECCS signal was generated by plant conditions and the operator put all ECCS pumps in pull-to-lock position, although no ECCS discharge occurred, the event is reportable.

A " valid signal" refers to the actual plant conditions or parameters satisfying the requirements for ECCS initiation. Valid actuations also include intentional manual actuations, unless the actuation is part of a preplanned sequence during test or operation. Excluded from this reporting requirement would be those instances in which instrument drift, spurious signals, human error. Or other invalid signals caused actuation of the ECCS (e.g., jarring a cabinet, an error in the use of jumpers or lifted leads, an error in the actuation of switches or controls, equipment failure or radio frequency interference). However, such evenis may be reportable under other criteria; in particular, if an ESF is actuated $50.72(b)(2)(ii) requires a report within four heurs and $50.73(a)(2)(iv) requires submittal of an LER.

The steif considers deliberate manual ECCS initiations or actuations based on the operator's understanding of actual plant conditions or parameters as valid signals. However, inadvertent manual ECCS initiations or actuations that occur because of human error, such as errors that occur during surveillance tests or maintenance activities, are not considered as valid signals. If the ECCS discharged or should have discharged into the reactor coolant system as a result of an invalid signal, no ENS notification under this reporting criterion is required. (Such a condition may be reponable as an ESF actuation under 10 CFR 50.72(b)(2)(ii).)

Any event reportable undst 650.72(b)(1)(iv) also requires a 30-day LER under $50.73(a)(2)(iv) because an ESF was actuated.

45 NUREG-1022, Rev.1

1 Examoles (1)

BWR Scram and ECCS Injection on Valid S,gnal A loss of instrument air caused the feedwater pump minimum flow valves to fail open and decrease reactor vessellevel. This resulted in an automatic reactor scram / turbine trip and high pressure core spray and reactor core isolation cooling injection into the reactor vessel for 4 minutes. After reactor vessel level and the condensate tad feedwater systems were restored, these pumps were secuied.

An ENS notification is required under 950.72(b)(1)(iv) because an ECCS system injected water into the RCS as a result of a va!'d ECCS signal. Although the RPS actuation also is reportable within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months under $50.72(b)(2)(ii), this more limiting criterion applies. An LER is required under $50.73(a)(2)(iv) because an ESF actuation occurred.

(2)

PWR ECCS Injection following Surveillance Testing While makag preparations for a normal plant cooldown in Mode 5, the licensee performed stroke time testing of the safety injection isolation valves. Following the test these valves were not returned to the closed position. This resulted in approximately 2000 gallons of borated water injecting into the reactor coolant system when the plant was depressurized below the safety iniection tank pressure of 260 psia.

This event is reportable as an ECCS injection under $50.72(b)(1)(iv). ECCS initiation was based on RCS pressu,% being less than safety irjection tank pressure. Therefore, ECCS initiation is considered to result from a valid signal. An LER is required under

$50.73(a)(2)(iv).

(3)

PWR ECCS Injection Caused by Personnel Error While surveillance testing containment isolation valves, a tast push-button was 4

inadvertently released, which initiated a "B" train containment isolation and ECCS.

High-pressure ECCS pumps in.iected 300 gallons of borated water from the refueling water storage tank into the reactor before the "B" pumps were secured while the reactor 4

remairied at 94-percent power.

This event is not reportable under 50.72(b)(1)(iv), even though it was an ECCS injection into the RCS, because it resulted from an invalid signal; however, it is raportable as an ESF actuation under @50.72(b)(2)(ii) and an LER is required under

$50.73(a)(2)(iv).

NUREG-1022, Rev.1 46

T 3.2.7 Loss of Emergency Preparedness Capabilities

. 650.72(b)(1)(v).

10 CFR 50.73 Licensees shall report: "Any event that

[No corresponding Part 50.73 requirement.)

results in a major loss of emergency assessment capability, offsite response capability, or communications capability (e.g., significant portion of control room F

indication, Emergency Notification System, 1

or offsite notification system),"

t If not reported as an emergency under 50.72(a), licensees are required to notify the NRC of a major loss of their emergency assessment, offsite response, or communications capability as soon as practical and in all cases within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

- Discussion i -

This reporting requirement pertains to events that would impair a licensee's ability to deal with an accident or emergency. Notifying the NRC of these events may permit the NRC to take

- some compensating measures and to more completely assess the consequences of such a loss should it occur during an accident or emergency.

Examples of events that this criterion is intended to cover are those in which any of the

]

foilowing is not available:

Safety parameter display system (SPDS) t Emergency response facilities (ERFs) e 1-Emergency communications facilities and equipment including the emergency notification system (ENS) i i

L Public prompt notification system including sirens e

Plant monitors necessary for accident assessment These and other situations should be evaluated for reportability as discussed below.

Loss of Emeroency Assessment Caoability

' l i

A mejor loss of emergency assessment capability would include those events that significantly impair the licensee's safety assessment capability. Some engineering judgment is needed to determine the significance of the loss of particular equipment, e.g., loss of only the SPDS for a 1

47 NUREG-1022, Rev.-1

--..-..c.-.

.n

'e-r 4

w

---.-s.--

., w

-.m u

_ _ _ _.. _ ~ _ _ _

j short period of time need not be reported, but loss of SPDS and other assessment equipment at the same time may be reportable.

The staff considers the loss of a significant portion of control room indication including annunciators or monitors, or the loss of all plant vent stack radiation monitors, as examples of a major loss of emergency assessment capability which should be evaluated for reportability.

Loss of Offsite Response Capabihty A major loss of offsite response capability includes those events that would significantly impair the fulfillment of the licensee's approved emergency plan for other than a short time. Loss of offsite response capability may typically include the loss of plant access, emergency offsite response facilities"8, or public prompt notification system, including sirens and other alerting

systems, if a lefgpetspug algniscent nebural hemordje.gtieerthrquehei huntoene, tomado,JIoodletc.) or other event causes pgedHeespelssed eveoussion veutes.to tpe imposeeds or other perte_of the l440110einheetiusbure to to)npelred to,the embent the$ the State and local govemments are rendered incapable of fulfilling their responsibilities in the emergency plan for the plant, then the NRC must be notified. This eoesLnot epplytrithe;oese:et.foutine treNio impediments euch as fagfspear ensliceMele~ met penderthe: state and local govemmente inospekte of fullinin0 meumspensamniosa wingendedje applyte more signiacent oness_such asJhe condulone lueussteumaksiteeint plant anerymftcano Andrew ebookMesa or the condisons around Moseper stellen eur!ns the tildwest soode:ofless; if the alert systems, e.g., sirens, are owned and/or maintained by others, the licensee should take reasonable measures to remain informed and must notify the NRC if a large number of sirens fail. Although the loss of a single siren for a short time is not a major loss of offsite response capability, the loss of a large number of sirens, other alerting systems (e.g., tone alert radios), or more importantly, the lost capability to alert a large segment of the population for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months would warrant an immediate notification.

Loss of Communications Capabihty A major loss of communications capability may include the loss of ENS and/or other offsite communication systems. The other offsite communication systems may include a dedicated telephone communication link to a State or a local govemment agency and emergency offsite response facilities, in-plant paging and radio systems required for safe plant operat;on, or commercial telephone lines.

Should either or both of the emergency communications subsystems (ENS and HPN) fall, the NRC Operations Center should be so informed over normal commercial telephone lines. When notifying the NRC Operations Center, licensees should use the backup commercial telephone 8%7ARIW5511115peskestreJpaintenanos on en ojellejamergencyresponse teollityAnot Igpeastett!ne:steunteentofutumed te_ service prompuymmevent of an soaidenti NUREG-1022, Rev.1 48

numbers provided. This satisfies the guidance provided in previous Information Notices 85-44

" Emergency Communication System Monthly Test," dated May 30,1985 and 86-97

" Emergency Communications System," dated November 28,1986, to test the backup means of communication when the primary system is unavailable as well as the reporting requirements of

$50.72(b)(1)(v). If the Operations Center notifies the licensee that an ENS line is inoperable, there is no need for a subsequent licensee notification. Loss of either ENS or HPN does not generate an event report. The Operations Center contacts the appropriate repair organization.

In a similar manner, if the NRC supplied telephone line or modem used for the emergency response data system is inoperable, the NRC operations center should be informed so that repairs can be ordered; However, this does not generate an event report.

Examoies (1)

Plant Access Roads Closed by Storm The local sheriff notified the licensee that all roads to and from the plant were closed because of a snow storm. The licensee had two full-shift crews on site to suppcrt plant operations and no emergency declaration was made. The licensee notified State and local authorities of the situation and made an ENS notification. The licensee deactivated its station isolation procedures after the storm passed and the roads were passable.

An ENS notification was made because the licensee determined that the road closing constituted a major loss of emergency offsite response capability. No LER is required.

(2)

Loss of Public Prompt Notification System ENS notifications of the loss of the emergency sirens or tone alert radios vary according to the licensee's locale and interpretations of " major loss" and have included:

12 of 40 county alert sirens disabled because of loss of power as a result of e

severe weather.

28 of 54 alert sirens were reported out of service as a result of a local ice storm.

All offsite emergency sirens were:

- found inoperable during a monthly test.

- taken out of service for repair.

- inoperable because control panel power was lost.

-inoperable because the county radic transmitter failed.

An ENS notification is required because of the major loss of offsite response capability, i.e., the public prompt notification system. However, licensees may use engineering judgment in determining reportability (i.e., a " major loss") based upon such factors as the percent of the population not covered by emergency sirens and the existence of 1

l 49 NUREG-1022, Rev.1

_= - _

. -.. - ~ - _ - - - -...

4 procedures or practices to compensate for the lost emerg9ncy sirens. An LER is not required because there is no corresponding 10 CFR 50.73 requirements.

(3)

Loss of ENS and Commercial Telephone System The licensee determined that ENS and commercial telecommunications capability was lost to the control room when a fiber optic cable was severed during maintenance. A communications link was established and maintained between the site and the load dispatcher via microwave transmission. Both the ENS and commercial communications capability were restored approximately 90 minutes later.

An ENS notification is required because of the major loss of communications capability.

Although the microwrave link to the site was established and maintained during the telephone outage, this in itself does not fully compensate for the loss of communication that would be required in the event of an emergency at the plant. No LER is required because there is no corresponding 10 CFR 50.73 requirements.

(4)

Loss of Direct Communication Line to Police The licensee contacted the State Police via commercial telephone lines and reported to the NRC Operations Center that the direct telephone line to the State Police was inoperable for over 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The licensee notified the NRC Operations Center in a followup ENS call that the line was restored to operability.

An ENS notification would be required if the loss of the direct telephone line(s) to various police, local, or State emergency or regulatory agencies is not compensated for by other readily available offsite communications systems In this example, no ENS notification is required since commercial telephone lines to

.e State Police were available. No LER is required because there is no corresponding 1v CFR 50.73 requirements.

NUREG-1022, Rev.1 50

3.2.8 Intemal Threat to Plant Safety

$50.72(b)(1)(vi)

$50.73(a)(2)(x)

Licensees shall report: "Any event that Licensees shall report: "Any event that poses an actual threat to the safety of the posed an actual threat to the safety of the nuclear power plant or significantly hampers nuclear power plant or significantly site personnelin the performance of duties hampered site personnel in the performance necessary for the safe operation of the of duties necessary for the safe operation of nuclear power plant including fires, toxic gas the nuclear power plant including fires, toxic releases, or radioactive releases."

gas releases, or radioactive releases."

If not reported as an emergency under $50.72(a), licensees are required to report such an event or condition to the NRC via the ENS as soon as practical and in all cases within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Licensees are required to submit an LER within 30 days.

Discussion These criteria pertain to intemal threats. The criteria for external threats,550.72(b)(1)(lii) and

$50.73(a)(2)(iii), are described in Section 3.2.5.

This provision requirer.eporting events, particularly those caused by acts of personnel, which endanger the safety of the plant or interfere with personnelin the performance of duties necessary for safe plant operations.

The licensee must exercise some judgment in reporting under this ruic. For example, a small fire on site that did not endanger any plant equipment and did not and could not reasonably be expected to endanger the plant is not reportable.

As indicated in the Statement of Considerations the phrase "significantly hampers site personnel" applies narrowly, i.e. only to those events which significantly hamper the ability of site personnel to perform safety-related activities affecting plant safety?"

in addition, the staff considers the following standards appropriate in this regard:

The significant hampering criterion is pertinent to "the performance of duties necessary for safe operation of the nuclear power plant." One way to evaluate this is to.ask if one could seal the room in question (or disable the function in question) for a substantial period of time and still operate the plant. safely, For exampleitf a switchgear room is unavailable for a time, but it.is normally not necessary to enter the room for safe t

operation, and no need to; enter.the. room arises while it is unavailable, the event is not reportable under this criterion.

VM 48 FR 33856, July 26,1983.

51 NUREG-1022, Rev.1

)

Significant hampering includes hindering or interfering (such as with protective clothing e

or radiation work permits) provided that the interference or delay is sufficient to significantly threaten the safe operation of the plant.

Actions such as room evacuations that are precautionary would not constitute significant hampering if the necessary actions can still be performed in a timely manner.

Plant mode may be considered in determining if there is an actual internal threat to a plant.

However, licensees should not incorrectly assume that everything that happens while a plant is shut down is unimportant and not reportable.

In-plant releases must be reported if they require evacuation of rooms or L Jildings containing systems imponent to ;;'cty and, as a result, the ability of the operators to perform necessary duties is si[,nificantly hampered.

Events such as minor spills, small gaseous waste releases, or the disturbance of contaminated particulate matter (e g., dust) that require temporary evacuation of an individual room until the airborne concentrations decrease or until respiratory protection devices are used, are not reportable unless the ability of site personnel to perform necessary safety functions is significantly hampered.

No LER is required for precautionary evacuations of rooms and buildings that subsequent evaluation determines were not required. Even if an evacuation affects a major part of the facility, the test for repor1 ability is whether an actual threat to plant safety occurred or whether site personnel were significantly hampered in carrying out their safety responsibilities.

In most cases, fires result in ENS notification because there is a declaration of an emergency class, which is reportable under $50.72(a)(1)(ii) as discussed in Section 3.1.1 of this report."

If there is an actual threat or significant hampering, an LER is also required. With regard to control room fires, the staff generally considers a control room fire to constitute an actual threat and significant hampering."

W As indicated in NUREG-0654, Rev.1, Information Notice 88-64 and Regulatory Guide 1.101, Rev. 3 (which endorses NUMARC/NESP-007, Rev. 2), a fire that lasts longer than 10 or 15 minutes or which affects plant equipment important for safe operation would result in declaration of an emergency class.

A It is theoretically possible to have a control room fire which is discovered and extinguished quickly and, even in this location, does not significantly hamper the operators and does not threaten plant safety. Examples could include small paper fires in ash trays or trash cans, or cigarette burns of fumiture or upholstery, NUREG-1022, Rev.1 52

Examoles (1)

Fires e

Question:

if we have a fire in the refueling bridge and we are not movit.g fuel, would the fire be reportable?

Answer.

No. If the plant is not moving fuel and the fire does not otherwise threaten other safety equipment and does not hamper site personnel, the fire is not reportable. If the plant is moving fuel, the fire is reportable.

l e

Question:

if we have a fire in the reactor building that forces contractor personnel who are doing a safety related modification to leave, but the fire did not hamper operations pesonnel or equipment, would that fire be reportable?

Answer; No. The fire would not be reportable if the fire was not severe enough that it posed an actual threat to the plant and the delay in completing the modification did not significantly threaten the safe operation of the plant, 1

53 NUREG-1022, Rev.1 4-p r--

+r 9

1 3.3 Four-hour ENS Notifications and LERs This section addresses $50.72(b)(2), "Non-Emergency Events-Four-Hour Reports," and 10 CFR 50.73 written reports associated with these 50.72 notifications. If not reported as a declaration of emergency class under $50.72(a) or as a non-emergency 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months report under

$50.72(b)(1), licensees are to notify the NRC as soon as practical and in all cases within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of the occurrence of any of the events required by 650.72(b)(2) and to submit an LER within 30 days for any event or condition required by 10 CFR 50.73.

In addition to events reportable under both 10 CFR 50.72 and 50.73, several requirements for 50.72 notifications only or LERs only are included in this section because of the sequential numbering scheme used. For examplo, common-mode failures of channels, trains, or systems, as discussed in Section 3.3.4, requiro LERs, but no ENS notifications are explicitly required unless reportable under other criteria. Transport of a contaminated person to an offsite medical i

facility, as discussed M Section 3.3.6, requires ENS notification but no LER.

1 l

l NUREG-1022, Rev.1 54

3.3.1 Shutdown Plant Found in Degraded or Unanalyzed Condition

_ $50.72(b)(2)(1) 10 CFR 50.73 Licensees shall report: "Any event found

[ Events found while the reactor is shutdown while the reactor is shut down. that, had it that involve degradation of the principal been found while the reactor was in safety barriers or unanalyzed conditions that operation. would have resulted in the significantly compromise plant safety are nuclear power plant, including its principal addressed by 650.73(a)(2)(ii). Therefore, an safety barriers, being seriously degraded or LER is required. See Section 3.2.4.]

being in an unanalyzed condition that significantly compromisen plant safety."

4 e

if not reported under @50.72(a) or (b)(1), licensees are required to report any such condition to l,

the NRC via the ENS as soon as practical, and in all cases within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of discovery of the condition. Licensees are required to submit an LER within 30 days.

Discussion Guidelines for identifying events that would result in the nuclear power plant being seriously degraded or being in an unanalyzed condition that significantly compromises plant safety are discussed in Section 3.2.4 of this report.

Examoles (1)

Significant Degradation of Reactor Fuel Rod Cladding Identified During Testing of Fuel Assemblies Radio-chemistry data for a particular PWR indicated that a number of fuel rods had 4

failed during the first few months of operation. Projections ranged from 6 to 12 failed rods. The end of cycle reactor coolant system iodine-131 activity averaged 0.025 micro curies per milliliter, following the end of cycle shutdown, iodine-131 spiked to 11.45 micro curies per milliliter. The cause was due to a significant number of failed fuel rods.

Inspections revealed that 136 of the total 157 fuel assemblies contained failed fuel (approximately 300 fuel rods had through-wall penetrations), far exceeding the anticipated number of failures. The defects were generally pinhole sized. The fuel cladding failures were caused by long-term fretting from debris that became lodged between the lower fuel assembly nozzle and the first spacer grid, resulting in penetration of the stainless steel fuel cladding. The source of the debris was apparently a machining byproduct from the thermal shield support system repairs during the previous refueling outage.

- An ENS notification is required because a principal safety barrier (the fuel cladding) was found seriously degraded. An LER is required.

55 NUREG-1022. Rev.1

~

(2)

Corrosion of a Control Rod Drive Mechanism Flange Resulted in a Reactor Coolant System Pressure Boundary Degradation While the plant was in hot shutdown, a total of six control rod drive mechanism (CRDM) reactor vessel nozzle flanges were identified as leaking. Subsequently one of the flanges was found eroded and pitted. While removing the nut ring from beneath the flange, it was discovered that approximately 50 percent of one of the nut ring halves had corroded away and that two of the four bolt holes in the corroded nut ring half were degraded to the point where there was no bolt / thread engagement.

An inspection of the flanges and spiral wound gaskets, which were renaved from between the flanges, revealed that the cause of the leaks was the gradual deterioration of the gaskets from age. A replacement CRDM was installed and the gaskets on all six CRDMs were replaced witn new design graphite-type gaskets.

An ENS notification is required because the condition caused a significant degradation of the RCS pressure boundary. An LER is required.

(3)

Significant Degradation of Reactor Fuel Rod Cladding Identified During Fuel Sipping Operations With the plant in cold shutdown, fuel sipping operations identified a significant portion of cycle 2 fuel, type "LYP," had failed, i.e., four confirmed and twelve potential fuel leakers.

The potential fuel leakers had only been sipped once prior to making the ENS notification. The licensee contacted the fuel vendor for assistance on-site in evaluating this problem.

As in example (1), an ENS notification was made because a principal safety barrier (the fuel cladding) was found seriously degraded. However, additional sipping operations and a subsequent evaluation by the licensee's reactor engineering department with vendor assistance concluded that no additional fuel failures had occurred, i.e., the abnormal readings associated with the potential fuel leakers was attributed to fission products trapped in the crud layer. Based on the results of the evaluation the licensee concluded that the fuel cladding was not seriously degraded and that the event was not reportable. Consequently, after discussion with the Regional Office, the licensee retracted this event.

NUREG-1022, Rev.1 56

3.3.2 Actuation of an Engineered Safety Feature or the RPS 550.72(b)(2)(li) 550.73(a)(2)(iv)

Licensees shall report "any event or Licensees shall report "any event or condition that resultiin a manual or condition that resultd in a manual or automatic actuation of any Engineered automatic actuation of any Engineered Safety Feature (ESF), including the Reactor Safety Feature (ESF), including the Reactor Protection System (RPS) except when:

Protection System (RPS), except when:

(A) The actuation results from and is part of (A) The actuation resultd from and was the preplanned sequence during testing or part of a pre-planned sequence during reactor operation; testing or reactor operation; (B) The actuation is invalid and:

(B) The actuation Wan invalid and:

(1) Occurs while the system is (1) Occurrg while the system was properly removed from service; properly removed from service; (2) Occurs after the safety function has (2) Occurrd after the safety function had been already completed; or been already completed; or (3) Involves only the following specific (3) Involved only the following specific I F.SFs or their equivalent systems; ESFs or their equivalent systems; (i) Reactor water clean-up system; (i) Reactor water clean-up system; (ii) Control room emergency ventilation (ii) Control room emergency ventilation system; system; (iii) Reactor building ventilation system; (iii) Reactor building ventilation system; (iv) Fuel building ventilation system; or (iv) Fuel building ve.itilation system; or (v) Auxiliary building ventilation system."

(v) Auxiliary building ventilation system."

If not reported under @50.72(a) or (b)(1), licensees are required to report any engineered safety feature actuation, including the reactor protection system, to the NRC via the ENS as soon as practical and in all cases within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of the event. Licensees are required to submit an LER within 30 days.

Discussion The Statements of Considerations indicate that this paragraph requires events to be reported whenever an ESF actuates either manually or automatically, regardless of plant status. It is based on the premise that tne ESFs are provided to mitigate the consequences of a significant event and, therefore: (1) they should work properly when called upon, and (2) they should not be challenged frequently or unnecessarily. The Commission is interested both in events where an ESF was needed to mitigate the consequences (whether or not the equipment performed properly) and events where an ESF actuated unnecessarily. In discussing the reporting of actuations which are part of preplanned procedures, the Statements of Considerations also state that actuations that need not be reported are those initiated for reasons other than to 57 NUREG-1022, Rev.1 1

mitigate the consequences of an event (e.g., at the discretion of the licensee as part of a preplanned procedure).W)

This indicates an intent to require reporting actuations of features that mitigate the consequences of significant events. Usually, the staff would not. consider this to include single

- component autuations because single components of complex systemsi by themselves, usually do not mitigate.the conesquences_of significant events.1However, in some cases a component would be sufficient to mitigate the event (l.o;, perform the ESF function) and its actuation would, 4

therefore; be reportable.; This position. is consistent with the statement that the reportmg requirement is based.on the promise that ESFs are provided to mitigate the consequences of a significant event?

Single trains.do mitigate the consequences, and, thusi train level actuations are reportable.

In this regard, the staff considers actuation of a diesel-generator to be actuation of a train-not actuation of a single component Mbecause_ a diesel generator mitigates the event (performs the ESF function for plants at which diesel generators are classified as ESF systems).1(See Example 3 below.)

The staff.also considers intentional manual actions, in which one or more ESF components are actuated in response to actual _ plant conditions resulting from equipment. failure or human.orror, to.be reportable because such actions would usually mitigate _the consequences of a significant eventJThis position is consistent with the statement that the commission is interested in events where an ESF was needed to mitigate the consequences of the event.f For example; starting a safety ir$ection pump.in response.to a rapidly decreasing pressurizer level or starting HPCI.in. response to a loss of feedwater would be_ reportablen Howeveri shifting alignment of makeup pumps otclosing a containment isolation valve for normalloperational purposes would not be_ reportable.

The Statement of Considerations also indicates that " actuation" of multichannel ESF actuation systems is defined as actuation of enough channels to complete the minimum actuation logic.

Therefore, single channel actuations, whether caused by failures or otherwise, are not reportable if they do not complete the minimum actuation logic.<22) Noteihoweverithat if only_a single logic channel actuates _when, in fact, the ESF system should have actuated in response to pla_nt parameters, this would be reportable'as_ an ESF failure.JThe _ event would. be reportable under these criteria (ESF actuation) as well as under_10 CFR 50.72(b)(2)(iii) and 10 CFR :

50.73(a)(2)(v)_(event or condition alone).;This position is consistent with the statement that the

- Commission.is interested in events where3n ESF was needed to mitigate the consequences; whether or not the equipment performed properly.i233 W) 48 FR 33854, July 28,1983,48 FR 39043 and 48 FR 39044, August 29,1983.

(22) 48 FR 33854, July 28,1983,48 FR 39043 and 48 FR 39044, August 29,1983.

(23) Also see 48 FR 39043, August 29,1983, which states that this paragraph is

. intended to capture events during which an ESF actuates or fails to actuate.

NUREG-1022, Rev.1 58

With regard to preplanned actuations, the Statements of Consideration indicate that operation of an ESF as part of a planned test or operational evolution need not be reported. Preplanned actuations are those which are expected to actually occur due to preplanned activities covered by procedures. Such actuatiom cre those for which a procedural step or other appropriate documentation indicates the specific ESF actuation that is actually expected to occur. Control room personnel are aware of the specific signal generation before its occurrence or indication in the control room. However, if during the test or evolution, the ESF actuates in a way that is not part of the planned evolution, that actuation should be reported. For example, if the normal reactor shutdown procedure requires that the control rods be inserted by a manual reactor scram, the reactor scram need not be repor:sd. However, if unanticipated conditions develop during the shutdown that cause an automatic reactor scram, such a reactor scram should be reported. The fact that the safety analysis assumes that an ESF will actuate automatically during an event does not eliminate the need to report that actuation. Actuations that need not be reported are those initiated for reasons other than to mitigate the consequences of an event (e.g., at the discretion of the licensee as part of a planned evolution)."*)

Note that if an operator were to manually scram the reactor in anticipation of receiving an automatic reactor scram, this would be reportable just as the automatic scram would be reportable.

On September 10,1992, the Commission published final amendments to 10 CFR 50.72 and 50.73 that apply to reporting of ESF actuations. Three categories of invahd ESF actuations are not reportable. These three categories are invahd ESF actuations of (1) systems which had been properly removed from service, or (2) systems for which the safety function which the ESF is intended to accomplish had already been accomplished, and (3) several specific systems listed below.

Valid ESF actuations are those actuations that result from " valid signals" or from intentional manualinitiation, unless it is part of a preplanned test. Valid signals are those signals that are initiated in response to actual plant conditions or parameters satisfying the requirements for ESF initiation. Note this definition of " valid" requires that the initiation signal must be an ESF signal. This distinction eliminates actuations which are the result of non-ESF signals from the class of valid actuations. Invalid actuations are, by definition, those that do not meet the criteria for being valid. Thus, invalid actuations include actuations that are not the result of valid signals and are not intentional manual actuations, invalid ESF actuations that occur when the system is already properly removed from service are not reportable if all requirements of plant procedures for removing equipment from service have been met. This includes required clearance documentation, equipment and control board tagging, and properly positioned valves and power supply breakers. In addition, invalid ESF actuations that occur after the safety function has already been completed are not reportable An example would be RPS actuation after the control rods have already been inserted into the core.

"'I 48 FR 33854, July 28,1983,48 FR 39043 and 48 FR 39044, August 29,1983.

59 NUREG-1022, Rev.1

)

Finally, invalid actuations for several specific systems or their equivalent are not reportable.

These systems are the reactor water clean up system in boiling water reactors (BWRs), the control room emergency ventilation system, the reactor building ventilation system (RBVS), the fuel building ventilation system, and the auxiliary building ventilation system. Thus, reportinr, of invalid actuations for these specific systems due to signals that originated from non-ESF circuitry are not required.

Invalid actuations of other ESF systems continue to be reportable. For BWRs, the actuation of the standby gas treatment system following an invalid actuation of the RBVS is also not reportable.

If an invalid ESF actuation reveals a defect in the ESF system so the system failed or would fail to perform its intended function, the event continues to be reportable ur. der other requirements of 10 CFR S0.72 and 50.73. When invalid ESF actuations excluded by the conditions described above occur as part of a reportable event, they should be desenbed as part of the reportable event, in order to provide a complete, accurate and thorough description of the event.

The reporting criterion "is based on the premise that ESFs are provided to mitigate the consequences of a significant event..'95) Systems typically reported under this criterion include the systems listed in Table 2. These are systems required to mitigate significant events and include ECCS, RPS, containment systems and certain auxiliary and support systems required to perform ESF functions. These are systems that are described in the FSAR and are required to satisfy ESF functional requirements. The NRC staff considers these systems to be a reasonable interpretation of what constitutes systems "provided to mitigate the consequences of a significant event."

Examoles (1)

RPS Actuation The licensee was placing the residual heat removal (RHR) system in its e

shutdown cooling mode while the plant was in hot shutdown. The BWR vessellevel decreased for unknown reasons, causing a RPS scram and Group lli primary containment isolation signals, as designed. All control rods had been previously inserted and all Group til isolation valves had been manually isolated. The licensee isolated RHR to stop the decrease in reactor vessellevel.

This event is reportable within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months under this criterion because, although the systems' safety functions had already been completed, the RPS scram and primary containment isolation signals were valid and the actuations were not part of the planned procedure. The automatic signals were valid because they were generated from the sensor by measurement of an actual physical system parameter that was at its set point. An LER is required.

<258 48 FR 33854, July 26,1983.

NUREG-1022, Rev.1 60

With the BWR defueled, an invalid signal actuated the RPS. There was no component operation because the control rod drive system had been properly removed from service. This event is no' reportable because (1) the RPS signal was invalid, add (2) the system had been properly removed from service.

An immediate notification (950.72) was received from a BWR licensee. In the reported event, both recirculation pumps tripped as a result of a breaker problem. This placed the plant in a condition in which BWRs are generally scrammed to avoid potential power / flow oscillations. At this plant, for this condition, a written off-normal procedure required the plant operations staff to scram the reactor. The plant staff performed a reactor scram which was uncomplicated. This event is reportable as a manual RPS actuation. Even though the reactor scram was in response to an existing written procedure, this event does not involve a preplanned sequence because the loss of recirculation pumps and the rnultant off-normal procedure entry were event driven, not preplanned. An t ER is required. In (nis case, the licensee initially retracted the ENS notification believing that the event was not reportable. After staff review and further discussion, it was agreed that the event is reportable for the reasons discussed above.

(2)

BWR Control Rod Block Monitor Actuation A rod block that was part of the planned startup procedure occurred from the rod block monitor, which, at this plant, is classified as a portion of the RPS or as an ESF.

This. event is not reportable. cause it occurred as a part of a preplenned startup procedure that specified certain rod blocks were expected to occur.-

(3)

Emergency Diesel Generator (EDG) Starts The licensee provided an LER describing an event in which the EDG automatically started when a technician inadvertently caused a short circuit that de-energized an essential bus during a calibration. An ENS notification and LER are required because the EDG auto-start (ESF actuation at this plant) was not identified at the step in the calibration procedure being used.

The licensee provided an LER describing an event in which, after an automatic EDG start, and for unknown reasons, the emergency bus feeder breaker from the EDG did not close when power was lost on the bus. An ENS notification and LER are required because the actuation logic for the EDG start (ESF actuation at this plant) was completed, even though the diesel generator did not power the safety buses.

61 NUREG-1022, Rev.1

(4)

Preplanned Manual Scram During a normal reactor shutdown, the reactor shutdown procedure required that reactor power be reduced to a low power at which poir't the control rods were to be inserted by a manual reactor scram. The rods were manually scrammed.

This event is not reportable because the manual scram results from and is, by procedure, part of a preplanned sequence of reactor operation. However,if conditions develop during the process of shutting down that require an unplanned reactor scram, the RPS actuation (whether manually of automatically produced) is reportable via ENS notification and LER.

(5)

Actuation of Wrorig Component During Testing During surveillance testing of the main steam isolation valves (MSIVs), an operator incorrectly closed MSIV "D" when the procedure specified closing MSIV "C."

This event is not reportabe because.the event 3c sii insdvertent actuation of a single component of an ESF system rather than F irain level actuation (and the purpose of the actuation was not to mitigate the conseqsences of an event),

(6)

Control Room Ventilation System (CRVS) Isolation While the CRVS was in service with no testing or maintenance in progress, a voltage transient caused spiking of a radiation monitor resulting in isolation of the CRVS, as designed.

This event is not reportable under this criterion becaur.e the event is due to an invalid signal and involves one of the four excepted systems (CRVS).

(7)

Reactor Water Cleanup (RWCU) Isolations The RWCU isolation valves closed in response to high water temperature, as designed. This is a common operational occurrence not indicative of a significant event; the initiation signal for this isolation is a non-ESF signal. As discussed above, this is an invalid actuation because it originates from a non-ESF signal and the event is not reportable because it is an invalid actuation of one of the four excepted systems.

An RWCU primary containment isolation (ESF actuation) occurred on pressurization between the RWCU suction containment isolation valves during the restoration of the RWCU system after a maintenance outage. An ENS notification and LER are required because a valid ESF signal initiated the RWCU isolation and the actuation was not part of a planned procedure.

l t

NUREG-1022, Rev.1 62

(8)

Manual Actuation of EEf Component in Respor.se to Actual Plant Condition At a PWR, maintenance personnelinacivertently pulled an instrument line out of a compression fitting connection at a pressure transmitter. The resultant reactor coolant system (RCS) leak was estimated at between 70 and 80 gpm. Charging flow increased due to automatic control system action. The operations staff recognized the symptoms of an RCS leak and entered the appropriate off normal procedure. The procedure directed the operations staff to start a second charging pump and flow was manually increased to raise pressurizer level. Based on the response of the pressurizer level, the operations staff determined that a reactor scram and safety injection were not necessary. Maintenance personnel still at the transmitter closed the instrument block and root valves terminating the event.

The staff considers the manual start of the charging pump (which also serves as an ECCS pump; but with a different valve lineup) In. response to dropping pressurizer level to.be an intentional manual actuation of an ESF in response to equipment failure or human error and reportable because it constitutes deliberate manual actuation of a single. component of an ESFiln resporise to plant conditions, to mitigate the consequences.of an event.;: As indicated in the Statements of Considerations for the rules "Actuations that need not be reported are those that are initiated for reasons other than_ to rpitigate the consequences of an event (e.g., at the discretion of the licensee as part of a planned procedure.or evolution)."A (9)

ESF Actuation During Maintenance Activity At a BWR, a maintenance activity was under way involving placement of a jumper to avoid ESF actuations. The maintenance staff recognized that there was a high potential for a loss of contact with the jumper and consequent ESF actuation. This potential was explicitly stated in the maintenance work request and on a risk evaluation sheet. The operating staff was briefed on the potential ESF actuatlons prior to start of work. During the event, a loss of continuity did occur and the ESF actuations involving isolation, standby gas treatment start, closing of some valves in the primary containment isolation system (recirculation pump seal mini-purge valve, nitrogen supply to drywell valve, and containment atmospheric monitoring valve) occurred.

The staff.has co.icluded that the event would not be reportable if the event were

. described in appropriate documentation as definitely _ expected to occur l However, since the event was not listed as definitely expected to occur and was not an intended result of the planned procedure, the event.is reportable.

48 FR 39043, August 29,1983, and 48 FR 33854, July 26,1983.

63 NUREG-1022, Rev.1 i

Table 2. Example Systems Emergency Core Cooling Systems (ECCS) for Pressurized Water Reactors (PWRs):

reactor coolant system accumulators boron injection system high, intermediate, and low-head injection systems, including systems for charging using centrifugal charging pumps, safety injection systems, and residual (decay) heat removal systems ECCS for Boiling Water Reactors (BWRs):

high-and low-pressure core spray systems high-pressure coolant injection system, feedwater coolant injection system, residual heat removal system (Iow pressure injection portion)

Isolation condenser system, reactor core isolation cooling system automatic depressurization system Containment Systems containment and reactor vessel isolation systems

=

containment neat removal and depressurization systems, including the containment spray and additive system and the fan cooler system containment air purification and cleanup systems containment combustible gas control systems, including hydrogen recombiners, igniters, and containment atmospheric dilution systems BWR standby gas treatment systems Electrical Systems emergency ac electrical power systems, including emergency diesel generators (EDGs) and their associated support systems and BWR dedicated Division 3 EDGs and their associated support systems actuation and control systems Heating, Ventitating and Air Conditioning (HVAC) Systems for Control Room and Fuel Handling Areas Anticipated Transient Without Scram (ATWS) Mitigating Systems PWR Auxiliary Feedwater Systems NUREG 3022, Rev.1 64

1

(.

4 3,3,3 Event or Condition That Alone Could Prevext Fulfillment of a Safety Function

$50.72(b)(2)(ill) 650.73(a)(2)(v)

Licensees chall report: "Any event or.

Jkenseos shall report: "Any event or condition that alone could have prevented condition that alone could have prevented the fulfillment of the safety functien of the fulfillment _of ths safety function of structures or systems that are needed to:

ctructures or systems that are needed to:

-(A) Shut down the reactor and maintain it (A) Shut down the reac*or and maintain it in a safe shutdown condition; in a safe shutdowr: conditun; (B) Remove residualheat; (B) Remove res dual heat; (C) Control the release of radioactive (C) Controlthe eiease of radioactive material; or material; or (D) Mitigate the consequences of an (D) Mitigate the sonsequences of an accident."

accident."

4 l

10 CFR 50.72 550.73(a)(2)(vi)

[The Statements of Consideration for 10

" Events covered in paragraph (a)(2)(v) of CFR 50.72 contain wording similar to those this section may include one or more of 650.73(a)(2)(vi).]

personnel errors, equipment failures, and/or discovery of design, analysis, fabrication, construction, and/or procedural inadequacies. However, individual component failures rieed not be reported -

pursuant to this paragraph if redundant equipment in the same system was operable and available to perform the required safety function".

If not reported under 150.72(a) or (b)(1), licensees shall notify the NRC via the ENS as soon as 7

practical and in all cases within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of discovery of the event or condition and submit an l.ER within 30 days.-

4 Discussion The level of Judgment for reporting an event or condition under this criterion is a_ reasonabie

- expectation _of preventing fulfillment of a_ safety function:::_In the discussions which follow, many of which are_taken from_the Statement of Considerations or from previous.NUREG_ guidance, several different. xpressions such as,"would have," "could.have " "alone could_ have,", and -

s

" reasonable doubt"sare used to characterize this standard.) In the staffs view l'all of these should be judged _on the basis of a reasonable expectation _ of preventing fulfillment _of the safety function.

65 NUREG-1022, Rev.1 =

As indicated in the Statement of ConsideratUns, the intent of these criteria is to capture those events where there would have been a failure of a safety system to propeny complete a safety function, regardless of when the failures were discovered or whether the system was needed at the time?4 These criteria cover an event or condition where redundant structures, components, or trains of a safety system could have failed to perform their intended function because of: one or more personnel errors, including procedure violations; equipment failures; inadequate maintenance; or design, analysis, fabrication, equipment qualification, construction, or procedural deficiencies. The event must be reported rer,ard' css of the situation or Ocnditan thet couecd the structure or systems to bc unav;";b';, and regardless of whether or not an alternate safety system could have been used to perform the safety function (e.g., high pressure core cooling failed, but feed-and-bleed or low pressure core cooling were available to provide the safety function of core cooling).

The definition of the systems included in the scope of these criterie is provided in the rules themselves; it is not determined by the phrases " safety-related" and "important to safety."

In determining the reportability of an event or condition that affects a system, it is not necessary to assume an additional random single failure in that system.

The term " safety function" refers to any of the four functions (A through D) listed in these reporting criteria that are required during any plant mode or accident situation as described or relied on in the plant safety analysis report or required by the regulations.

A system must operate long enough to complete its intended safety function as defined in the safety analysis report. Reasonable operator actions to correct minor problems may be considered, however, heroic actions and unusually perceptive diagnoses, particularly during stressful situations, should not be assumed. If a potentially serious human error is made that could have prevented fulfillment of a safety function, but recovery factors resulted in the error being corrected, the error is still reportable.

Both offsite electrical power (transmission lines) and onsite emergency power (usually diesel generators) are considered to be separate functions by GDC 17. If taner offsite power or unsite emergency power is unavailable to the plant (i e., completely lost), it is reportable regardless of whether the otner system is available GDC 17 defines the safety function of each system as providing sufficient capacity and capability, etc., assuming that the other system is not available. Loss of offsite power should be determined at the essential switchgear busses.

As indicated in the Statement of Considerations:

"The Commission recognizes that the application of this and other paragraphs of this section involves the use of engineering judgment. In this case, a technicaljudgment must be made whether a failure or operator action that did actually disable one train of a (2n 48 FR 33854, July 28,1983.

NUREG 1022, Rev.1 66

safety system, couH have, but did not, affect a redundant train within the ESF system.

If so, this would coristitute an event that "could have prevented" the fulfillment of a safety function, and, accordingly, must be reported.

If a component fails by an apparently random mechanism it may or may not be reportable if the functionally redundant component could fail by the same mechanism.

Reporting is required if the failure constitutes a condition where there is reasonable doubt that the functionally redundant train or channel would remain operational until it completed its safety function or is repaired. For example, if a pump in one train of an ESF system fails because of improper lubrication, and engineering judgment indicates that there is a reasonable expectation that the functionally redundant pump in the other train, which was also improperly lubricated, would have also failed before it completed its safety function, then the actual failure is reportable and the potential failure of the functionally redundant pump must be discussed in the LER.

For systems that include three or more trains, the failure of two or more trains should be reported if, in the judgment of the licensee, the functional capability of the overall system was jeopardized."W and:

" Finally, the Commission recognizes that the licensee may also use engineering judgment to decide when personnel actions could have prevented fulfillment of a safety function. For example, when an individualimproperly operates or maintains a component, he might conceivably have made the same error for all of the functionally redundant components (e.g., if he incorrectly calibrates one bistable amplifier in the Reactor Protection System, he could conceivably incorrectly calibrate a!l bistable amplifiers). However, for an event to be reportable it is necessary that the actions actually affect or involve components in more than one train or channel of a safety system, and the result of the actions must be undesirable from the perspective of protecting the health and safety of the public. The components can be functionally redundant (e.g, two pumps in different trains) or not functionally redundant (e.g., the operator correctly stops a pump in Train "A" and instead of shutting the pump discharge valve in Train "A," he mistakenly shuts the pump discharge valve in Train "B") "A Any time a system did not or could not have performed its safety function because of a single failure, common-mode failure, or combination of independent failures it is reportable under these criteria. These reporting requirements apply to the system level, rather than the train or component level.

W 48 FR 33854 and 48 FR 33858, July 26,1983.

W 48 FR 33854 and 48 FR 33858, July 29,1983.

67 NUREG-1022, Rev.1

p

$ N.

1 Single Failure These reporting criteria are not meant to require reporting of a single, independent (i.e.,

random) component failure that makes only one functionally redundant train inoperative unless it is indicative of a generic problem (i.e., has common-mode failure implications).

As indicated in Paragraph 50.73(a)(2)(vi) "... individual component failures need not be reported pursuant to this paragraph if redundant equipment in the same system was operable and available to perform the required safety function..."

The staff considers application of this principle to include cases where one train of a two train system is:

(1) failed, or; (2) otherwise incapable of performing its function because of factors such_ as operator error or design, analysis, fabocation, construction and/or procedural inadequacies, or; (3) in the case of a train which should be running, otherwise not performing its function because of factors such as operator error or design, analysis, fabrication,; construction and/or procedural inadequacies, or, (4) otherwise subject to a reasonable expectation of being prevented from fulfilling its safety function.

The staff believes that the conditions necessary to consider the redundant train operable and available, for this purpose, should include the following:

(1) in cases where the redundant train should operate automatically, it is capable of timely and correct automatic operation, or in cases where the redundant train should be operated manually, the operators would detectM the need for l'.s operation and initiate such operation, using established procedures for which they are trained..within.the needed time frame, without the need for trouble shooting and repair, and; (2) the redundant train is capable of performing its safety function for the duration required, and; MEFor example, conditions that would indicate a need for operation of the redundant train are regularly monitored and instrumentation used to monitor these conditions is capable and~available, NUREG-1022, Rev.1 68 l

(3) there is not a reasonable expectation of preventing fulfillment of the safety function by the redundant train."

A single failure that defeats the safety function of a system is reportable even if the design of the system, which allows such a single failure to defeat the function of the system, has been found acceptable.

As discussed in the Stateneont of Considerations, "there are a limited number of single-train systems that perform safety functions (e.g., the High Pressure Coolant injection System in BWRs). For such systems, loss of the single train would prevent the fulfillment of the safety function of that system knd, therefore, is reportable even though the plant technical specifications may allow sucn a condition to exis.t for a limited time."A e

Common-Cause Failures The following conditions are reportable under these criteria:

an event or condition that disabled multiple trains of a system because of a single cause an event or condition where one train of a system is disabled; in addition, (1) the underlying cause that disabled one train of a system could have failed a redundant train and (2) there is peesonable expectation that the second train would not complete its safety function if called upon an observed or identified event or condition that alone could have prevented fulfillment of the safety function Multiple equipment inoperability or unavailability Whenever an event or condition exists where the system could have been prevented from futfilling its safety function because of one or more reasons for equipment MMor exampleathis;rpeens_that the exclusiori from reporting. single component failures under,this' critetton (i.e:; Paragraphs 60.72(b)(2)(lii),;50.73(a)(2)(v) and 50.73(a)(2)(vi))

should not apply when there is a reasonable expectation of failure of the redundant train as.a tetulleHhe.same cause. Application of this principle is illustrated in several parts of this section, including: (1) the immediately proceeding quotations from 48 FR 33854 and 48 FR 33858; (2) the immediately following discussion of common cause failures, and; (3) the discussions in Examples 12 and 13. As indicated in the first paragraph of this section, the event should be reported under this criterion if there is a reasonable expectation of preventing fulfillment of the cafety function.

M 48 FR 33854, July 26,1983.

69 NUREG-1022, Rev.1

inoperability or unavailability, it is reportable under these criteria. This would include cases where one train is disabled and a second train fails a surveillance test.

1 Reputability of any of the above type failures (single, common-mode, or multiple) under both 10 CFR 50.72 and 50.73 is independent of power or plant mode. It also is independent of whether; the system or structure was demanded at the time of discovery e

the system or structure was required to be operable at the time of discovery e

the cause of a potential failure of the system was corrected before an actual demand for the safety function could occur other systems or structures were available that could have or did perform the safety e

function the entire system or structure is specified as ESF or safety related the problem occurs in a non-safety portion of a system a

The following types of events or conditions generally are not reportable under these criteria:

failures that affect inputs or services to systems that have no safety function (unless it could prevent the performance of a safety function of an adjacent or interfacing system) e a single defective component that was delivered, but not installed removal of a system or part of a system from service as part of a planned evolution for a

maintenance or surveillance testing when done in accordance with an approved procedure and the plant's TS (unless a condition is discover 6d that could have prevented the system from performing its function) independent failure of a single component (unless it is indicatlve of a generic problem, it e

alone could have caused a safety systern failure, or it is in a single-train system) a procedure error discovered before procedure approval and the error could have e

resulted in defeating the system function a failure of a system used only to wam the operator where no credit is taken for it in any e

safety analysis and it does not directly control any of the safety functions in the criteria a single stuck control rod that alone would not have prevented the fulfillment of a reactor e

shutdown unrelated component failures in several different safety systems a

NUREG-1022, Rev.1 70

The applicability of these criteria includes those safety systems designed to mitigate the-consequences of an accident (e.g., containment isolation, emergency filtration). Hence, minor operational events involving a specific component such as valve packing leaks, which could be considered a lack of control of radioactive material, should not be reported under this paragraph. System leaks or other similar events may, however, be reportable under other sections of the rules.A Examoles Sinale Train Systems (1)

Failure of a Single-Train System Preventing Accident Mitigation and Residual Heat Removal When the licensee was preparing to run a surveillance test, a high-pressure coolant injection (HPCI) flow controller was found inoperable; therefore, the licensee declared the HPCI system inoperable. The plant entered a technical specification requiring that the automatic depressurization, low-pressure coolant injection, core spray, and isolation condenser systems remain operable during the 7-day LCO or the plant had to be shut down. The licensee made an ENS notification within 28 minutes and a followup call after the amplifier on the HPCl flow transmitter was fixed and the HPCI retumed to operability.

As discussed above, the loss of a single train safety system such as BWR HPCl is reportable.

(2)

Failure of a Single-Train Non-Safety System Question; if RCIC is not a " safety system" in that no credit for its operation is taken in the safety analysis, are failures and unavailability of this system reportable?

Answer:

If the plant's safety analysis considered RCIC as a system needed to remove residual heat (e.g., it is included in the Technical Specifications) then its failure is reportaob under this criterion; otherwise, it is not reportable under this section of the rule.

A 48 FR 33854, July 26,1983.

71 NUREG-1022, Rev.1 -

k (3)

Failure of a Single-Train Environmental System Question:

There are a number of environmental systems in a plant dealing with such things as low level waste (e.g., gaseous radwaste tanks). Many of these systems are not required to meet the single failure criterion so a single failure results in the loss of function of the system. Are all of these systems covered within the scope of the LER rule?

Answer.

If such systems are required by Technical Specifications to be operational and the system is.needed to fulfill one _of the safety functions identified in. this section of _the _ rule then system leve: failures are reportable. If the system is not covered by Technical Specifications and is not required to meet the single failure criterion, then failures of the system are not reportable under this criterion.

Loss of Two Trains (4)

Loss of Onsite Emergency Power by Multiple Equipment inoperability and Unavailability During refueling, one emergency diesel generator (EDG) in a two train system was out of service for maintenance. The second EDG was declared inoperable when it failed its surveillance test.

An ENS notification is required and an LER is required. As addressed in the Discussion section above, loss of either the onsite power system or the offsite power system is reportable under this criterion.

(5)

Procedure Error Prevents Re ctor Shutdown Function The unit was in mode 5 (95'F and 0 psig ; before initial criticality) and a post-modification test was in progress on the train A reactor protection system (RPS), when the operator observed that both train A and B source range detectors were disabled.

During post-modification testing on train A RPS, instrumentation personnel placed the train B input error inhibit switch in the inhibit position. With both trains' input error inhibit switches in the inhibit position, source range detector voltage was disabled. The input errc inhibit switch was i.nmediately retumed to the normal position and a caution was added to appropriate plant instructions.

This event is reportcble because disabling the source range detectors could have prevented fulfillment cf the safety function to shut down the reactor.

(6)

Failure of the Overpressurization Mitigation System The ROS was overpressurized on two occasions during startup following a refueling outage because the overpressure mitigation system (OMS) failed to operate. The NUREG-1022, Rev.1 72

r i-reason that the OMS failed to operate was that one train was out of service for

' maintenance and a pressure transmitter was isolated and a summator failed in the actuation circuit on the other train.

o 4

- The event is reportable because the OMS failed to perform its safety function.

(7)

' Loss of Salt Water Cooling System and Flooding in Saltwater Pump Bay -

i During maintenance activities on the south saltwater pump, the licensee was removing the pump in'emah from ine casing when flooding of the pump area occurred. The north saltwater pump was secured to prevent pump damage.

The event is reportable because of the failure of the saltwster cooling system, which is the ultimate heat sink for the facility, to perform its safety function.

1 i

-(8)

Maintenance Affecting Two Trains

+ =

Question:

Some clarification is needed for events or conditions that alone "could have" prevented the fulfillment of a system safety function.

Answer:

4

" Events or conditions" generally involve operator actions and/or component failures that could have prevented the functioning of a safety system. For example, assume that a surveillance test is run on a standby pump and it seizes. The pump is disassembled and found to contain the wrong lubricant. The redundant pun.p is disassembled and it also has the same wrong lubricant. Thus, it is reasonable to assume that the second pump would have failed if it had been challenged. However, the second pump and, therefore, the system did not actually fail because the second pump was never -

challenged. Thus, in this case, because of the use of the wrong lubricant, the system "could have" or "would have" failed.

i i

Loss of One Train (9)-

. Oversized Breaker Wiring Lugs

' Situation:

During testing of 480 volt safety-related breakers, one breaker would not trip electrically.

Investigation revealed that one wire of the pigtail on the trip coil, although still in its lug,-

~

was so loose that there was no e%ctrical connection.1The Inose connection was due to the fact that the pigtail lug was too large (No.14-16 AWG), whereas the pigtail wire was 4

No. 20 AWG. A No.18-22 lug is the acceptable industry standard for a No. 20 AWG wire.

73 NUREGh102?

Since the trip coils were supplied pre wired, all safety-related breakers utilizing the trip I

coil were inspected. All other breakers inspected had No.14-16 AWG lugs. No lugs were found with loose electrical connections Nevertheless, all No.1416 AWG lugs were replaced with acceptable industry Standard No.18 22 AWG lugs.

Comment:

The event is reportable because the incompatible pigtails and lugs could have caused one or more safety systems to fail to perform their intended function [50.73(a)(2)(v)].

(10)

Contaminated Hydraulic Fluid Degrades MSIV Operation Situation:

During a ruutine shutdown, the operator noted that the #11 MSIV closing time appeared to be excessive. A subsequent test revealed the #11 MSIV shut within the required time, however, the #12 MSIV closing time exceeded the maximum at 7.4 sec.

Contamination of the hydraulic fluid in the valve actuation system had caused the system's check valves to stick and delay the transmission of hydraulic pressure to the actuator. Three more filters will be purchased providing supplemental filtering for each MSIV. Finer filters will be used in pump suction filters to remove the fine contaminants.

The #12 MSIV was repaired and returned to service. Since the valves were not required for operation at the time of discovery, the safety of the public was not affected.

Comments:

The event is reportable beenuse a single condition could have prevented fulfillment of a safety function [50.73(a)(2)(v)].

The fact that the condition was discovered when the valves were not required for operation does not affect the reportability of the condition.

(11)

Diesel Generator Lube Oil Fire Hazard Situation:

While performing a routine surveillance test of the emergency diesel generator, a small l

fire started due to lubricating oil leahage from the exhaust manifold. The manufacturer reviewed the incident and determined that the nil was accumulating in the exhaust l

l manifold due to leakage originating from above the upper pistons of this vertically opposed piston engine. The oil remaining above the upper pistons after shutdown l

leaked slowly down past the piston rings, into the combustion space, past the lower piston rings, through the exhaust ports, and into tne exhaust manifolds. The exhaust manifolds became pressurized during the subsequent startup which forced the oil out through leaks in the exhaust manifold gaskets wheie it was ignited.

NUREG-1022, Rev.1 74

Similar events occurred previously at this plant. In these previous cases, fuel oil accumulated in the exhaust manifold due to extended operation under "no load" conditions. Operation under loaded conditions was therefore required before shutdown in order to burn off any accumulated oil.

Comments:

The event is not reportable if the fire did not pose a threat to the plant (i.e., it only affected a single component) [50.73(a)(2)(x)).

The event would be reportable if it demonstrates a design, procedural, or equipment deficiency that could have prevented the fulfillment of a safety function (i.e., if the redundant diesels are of similar design and, therefore, susceptible to the same problem)

[50.73(a)(2)(v)).

(12)

Single Failures Question:

I notice that loss of relief / safety valve capability is reportable. Does this mean that an LER is required when one valve is inoperative? In addition, suppose your have one pump in a cooling water system (e.g., chilled water) supplying water to both trains of a safety system, but there is another pump in standby; is the loss of the one operating pump reportable?

Answer:

No. Single, independent (i.e., random) component failures are not reportable as LERs if the redundant component in thr, same system did or would have fulfilled the safety function. lr,,,;r. ore,', h;;.;;;r, euch ';ir;,; ;r; r;p.1;M; to th; NPRO ;y;;=.

However, if such failures have generic implications, then an LER is to be submitted.

(See the discussion under the heading " Single Failures" for further dircussion of reporting the loss of one train.)

(13)

Generic Setpoint Drift Situation:

Witn the plant in steady state operation at 2170 MWt and while performing a M9in Steam Line Pressure Instrument Functional Test and Calibration, a switch was found to actuate at 853 psig. The Tech Specs limit is 825 +15 psig. The redundant switches were operable. The cause of the occurrence was setrioint drift. The switch was recalibrated and tested successfully per HNP-2-5279, Barksdale Pressure Switch Calibration, and returned to service.

j 75 NUREG-1022, Rev.1

m This is a repetitive event as reported in one previous LER A generic review revealed that these type switches are used on other safety systems and that this type switch is subject to drift. An investigation will continue as to why these switches dnft, and if necessary, they will be replaced.

Comments:

The event is not reportable due to the drift of a single pressure switch.

The event is reportable if it is indicative of a generic and/or repetitive problem with this type of switch which is used in several safety systems (50.73(a)(2)(v) or (viii)).

Question:

Are setpoint drift problems with a particular switch to be reported if they are experienced more than once?

Answer:

The independent failure (e.g., excessive setpoint drift) of a single pressure switch is not reportable unless it alone could have caused a system to fail to fulfill its safety function, or is indicative of a generic problem that could have resulted in the failure of more than one switch and thereby cause one or more systems to fail to fulfill their safety function.

(14)

Maintenance Affecting Only One Train Question:

Suppose the wrong lubricant was installed in one pump, but the pump in the other train was correctly lubricated. Is this reportable?

Answer:

Engineering judgement is required to decide if the lubricant could have been used on the other pump, and, therefore, the system function would have been lost. If the procedure called for testing of the first pump before maintenance was performed on the second pump and testing clearly identified the error, then the error would not be reportable. However, if the procedure called for the wrong lubricant and eventually both pumps would have been improperly lubricated, and the problem was only dincovered when the first pump was actually challenged and failed, then the error would be reportable, NUF'EG-101'2, Rev.1 76

- - i

Other Conddions (15)

Conditions Observed While System Out of Service Question:

t Suppose during shutdown we are doing maintenance on both Si pumps, which are not required to be operational. Is this reportable? While shutdown, suppose 1 identify or observe something that would cause the Si pumps not to be operational at power, is this reportable?

Answer:

Removing both Si pumps from service to do maintenance is not reportable if the resulting system configuration is not prohibited by the plant's technical specifications.

However, if a situation is discovered during maintenance that could have caused both pumps to fail, (e.g., they are both improperly lubricated) then that condition is reportable even though the pumps were not required to be operational at the time that the condition was discovered. As another example, suppose the scram breakers were tested during shutdown conditions, and it was found that for more than one breaker, opening times were in excess of those specified, or that UV trip attachments were inoperative. Such potential generic problems are reportable in an LER.

(16)

Diesel Generator Bearing Problems During the annual inspection of one standby diesel generator, the lower crankshaft thrust bearing and adjacent main bearing were found wiped on the journal surface. The thrust bearing was also found to have a small crack from the main oil supply line across the journal surface to the thrust surface. Inspection of the second, redundant standby diesel generator annual inspection revealed similar problems. It was judged that extended operation without corrective action could have resulted in bearing failure.

The event is reportable because there was reasonable doubt that both diesels would have remained operable until they completed their safety function if called upon.

(17)

Potential Loss of High Pressure Coolant Injection During normal refueling leak testing of the upstream containment isolation check valve on the High Pressure Coolant injection (HPCI) steam exhaust, the disc of the non-t containi.1ent isolation check valve was found lodged in downstream piping. This might have prevented HPCI from functioning if the disc had blocked the line. The event was caused by fatigue failure of a disc pin.

Following evaluation of the condition, the event was determined to be reporteble because the HPCI could have been prevented from performing its safety function if the disc had blocked the line. In addition, the event is reportable if the fatigue failure is indicative of a common-mode failure.

l 77 NUREG-1022, Rev.1

(18)

Defective Component Delivered but not Installed Question:

How should a plant report a defective component that was delivered, but not installed?

Answer:

A single defective component would not generally be reportable (assuming that the problem has no generic implications). A generic problem or a number of defective components would probably constitute a condition that could have prevented fulfillment of a safety function, and, if so, would he reportable. Engineering judgment is required to determine if the defects could have weaped detection prior to installation and operation.

As a minimum, any generic problem may be reported as a voluntary LER. In addition, such a condition may be reportable under 10 CFR Part 21.

(19)

Operator inaction or Wrong Action Question:

In some systems used to control the release of radioactivity, a detector controls certain equipment. In other systems, a monitor is present and the operator is required to initiate action under certain conditions. The operator is not " wired"in. Are failures of the operator to act reportable?

Answer:

Yes. The operator may be viewed as a " component" that is an integral, and frequently essential, part of a " system " Thus, if an event or condition meets the criterion specified in 50.73 for reporting, it is to be reported regardless of the initiating cause (i.e., whether an equipment, procedure, or personnel error is involved).

(20)

Results of Analysis Question:

A number of criteria indicate that they apply to actual situations only and not to potential situations identified as a result of analysis; yet, other criteria address "could have."

When do the results of analysis have to be reported?

Answer:

The results need only to be reported if the applicable criterion requires the reporting of conditions that "could have" caused a problem. However, others have a need to know about potential problems that are not reportable; thus, such items may be reported as a voluntary LER.

NUREG 1022, Rev.1 78

7 (21)

System Interactions Question:

Utilities are not required to analyze for system interactions, yet the rule requires the reporting of events that "could have" happened but did not. Are we to initiate a design activity to determine "could have" system interactions?

l Answer:

No. Report system interactions that you find as a result of ongoing routine activities (e.g., the analysis of operating events).

l i

79 NUREG-1022, Rev.1

3.3.4 Common-cause Failures of Independent Trains or Channels 10 CFR 60,72 660.73(a)(2)(vii)

[No corresponding Part 50.72 requirement.)

Licensees shall report: "Any event where a single cause or condition caused at least one independent train or channel to become inoperable in multiple systems or two t

independent trains or channels to become inoperable in a single system designed to:

(A) Shut down the reactor and maintain it in a safe shutdown condition; (B) Remove residual heat; (C) Control the release of radioactive material; or (D) Mitigate the consequences of an accident."

i Licensees are required to report a common-cause failure as an LER within 30 days.

Discussion This criterion requires those events to be reported where a single cause or condition caused independent trains or channels to become inoperable. Commeteouses mey include such feelem se W entient tempesolume, hostup Wem enesgleellenl Inadesquete pmventive pneintenense, en sentemleellen.of air systems, inservest tulptoegen,~.ues of nelHlueNRed eemponents. or manulegeuring er deelen newe@ event is reportehlt ilt.the independent emine er ehennels wom ensperante et the same time, resensees of whosher er not they were discovered at the esme time,1(Exemple (2) below leustulos.e case,where the second failure was dgegevoted 3. days toler tien.the_tret.)

An event or failure that results in or involves the failure of independent portions of more than one train or channelin the same or different systems is reportable. For example, if a cause or condition caused components in Train "A" and *B" of a single system to become inoperable, even if additional trains (e.g., Train "C") were still available, the event must be reported, in addition, if the cause or condition caused components in Train "A" of one system and in Train "B" of another system (i.e., train that is assumed in the safety analysis to be independent) to become inoperable, the event must be reported. However, if a cause or condition caused components in Train "A" of one system and Train "A" of another system (i.e., trains that are not s

assumed in the safety analysis to be independent), the event need not be reported unless it meets one or more of the other reporting criteria.

Ifeins er ehennels ter saportablNiy purpenes. ore deAned as these redundant, independent Walps et.shennels designed to povide protection egelnet twiele.tellures; Many engineered selety,sgelems centelning sellve esmponente are designed wth et tenet a two train eyenema NUREG-1022, Rev.1 80

Each independent train in a two-train system can normally satisfy all the safety sysi,em requirements to safely shut down the plant or satisfy those criteria that have to bimet following en accident, This critsrion does not include those cases where one train of a system or a component was removed from service as part of a planned evolution, in accordance with an approved procedure, and in accordance with the plant's technical specifications. For example, if the licensee removes part of a system from service to perform maintenance, and the Technical Specifications permit the resulting configuration, and the system or component is retumed to service within the time limit specified in the Technical Specifications, the action need not be reported under this paragraph. However, if, while the train or component is out of service, the licensee identifies a condition that could have prevented the whole system from performing its intended function (e g, the licensee finds a set of relays that is wired incorrectly), that condition must be reported.

Analysis of events reported under this part of the rule may identify previously unrecognized common-cause (or dependent) failures and system interactions. Such failures can be simultaneous failures that occur because of a single initiating cause (i.e., the single cause or mechanism serves as a common input to the failures); or the failures can be sequential (i.e.,

cascading failures), such as the case where a single component failure results in the failure of one or more additional components.

Enn&a (1)

Incorrect Lubrication Degrades Main Steam isolation Valve Operation During monthly operability tests, the licensee found that the Unit 2B inboard MSIV did not stroke properly as a result of a solenoid-operated valve (SOV) failure. Both units were shut down from 100-percent power, and the SOVs piloting all 16 MSIVs were inspected. The licensee found that the SOVs on all 16 MSIVs were damaged. The three-way and four way valves and solenoid pilot valves on all 16 MSIVs had a hardened, sticky substance in their ports and on their O-rings. As a result, motion of all the SOVs was impaired, resulting in instrument air leakage and the inability to operate all of the MSIVs satisfacturily. The licerisee also exarr,;ned unused spares in the warehouse and found that the lubricant had dried out in those valves, leaving a residue.

Several of the warehouse spares were bench tested. They were found to be degraded and also leaked. The root cause of the event was use of an incorrect lubricant.

The event is reportable (a) because a single cause or condition caused multiple in63 pendent trains of the main steam isolation system (a system designed to control the release of radioactive material and mitigate the consequences of an accident) to become inoperable [$50,73(a)(2)(vii)(C and D)) and (b) because a single condition could

]

have prevented fulfillment of a safety function [950.73(a)(2)(v)).

81 NUREG-1022, Rev.1

l l

(2)

Marine Growth Causing Emergency Service Water To Become Inoperable (Common-Mode Failure Mechanism)

With Unit 1 at 74 percent power and Unit 2 at 100 percent power, ESW pump 1 A was declared inoperable because its flow rate was too low to meet acceptance criteria.

I Three days later, with both units at the same conditions, ISW pump 1C was declared inoperable for the same reason. The ESW pumps provide the source of water to the 7'

i intake canal during a design-basis accident. In both cases, the cause was marine growth of hydoids and barnacles on the impeller and suction of the pumps. Following maintenance, both pumps passed their performance tests and were placed in service.

Pump testing frequency was increased to more closely monitor pump performance.

This event is reportable because a single cause or condition caused two independent i

trains to become inoperable in a single system designed to mitigate the consequences of an accident [950.73(a)(2)(vii)(D)).

(3)

Testing Indicated Several Inoperable Snubbers The licensee found 11 inoperable snubbers during periodic testing. All the snubbers failed to lock up in tension and/or compression. These failures did not render their respective systems inoperable, but rendered trains inoperable. Improper lockup settings and/or excessive seal bypass caused these snubbers to malfunction. These snubbers were designed for low probability seismic events. Numerous previous similar events have been reported by this licensee.

This condition is reportable because the condition indicated a generic common mode problem that caused numerous multiple independent trains in one or more safety systems to become inoperable. The potential existed for numerous snubbers in several systems to fail following a seismic event rendering several trains inoperable. [9 50.73(a)(2)(vii)]

(4)

Stuck High Pressure Injection (HPI) System Check Valves as a Result of Corroded Flappers The licensee reported that check valves in three of four HPI lines were stuck closed.

The unit had been shut down for refueling and maintenance.

A special test of the check valves revealed that three 2%-inch stop check valves remained closed when 130 pounds per square inch (psi) of differential pressure was applied to the valve. An additional test revealed that the valve failed to open when 400 psi of differential pressure (the capacity of the pump) was applied to the valve. Further review showed that the common cause of valve failure was the flappers corroding shut.

The event is reportable because a single cause or condition caused at least two independent trains of the HPI system to become inoperable. This system is designed to remove residual heat and mitigate the consequences of an accident. The condition is NUREG 1022 Rev.1 82

therefore reportable under 50.73(a)(2)(vii)(8 and D), common cause failure in systems designed to remove residual heat and mitigate accidents.

4 i

83 NUREG 1022, Rev.1

)

3.3.5 Airborne or Liquid Effluent Release

$50.72(b)(2)(lv) 550.73(a)(2)(vill)

I Licensees shall report:

Licensees shall report:

"(A) Any airborne radioactive release that,

"(A) Any airborne radioactivity release that, when averaged over a time period of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , when averaged over a time period of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , results in concentrations in an unrestricted resulted in airborne radionuclide area that exceed 20 times the applicable concentrations in an unrestricted area that concentration specified in Appendix B to exceeded 20 times the applicable Part 20, Table 2, Coluran 1.

concentration limits specified in Appendix B (B) Any liquid effluent release that, when to Part 20, Table 2 Column 1.

averaged over a time period of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , (B) Any liquid effluent release that, when exceeds 20 times the applicable averaged over a time period of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , concentration specified in Appendix B to exceeds 20 times the applicable Part 20, Table 2, Column 2, at the point of concentrationa specified in Appendix B to entry into the receiving waters (i.e.,

Part 20 Table 2, Column 2, at the point of unrestricted area) for all radionuclides entry into the receiving waters (i.e.,

except tritium and dissolved noble gases.

unrestricted area) for all radionuclides (Immediate notifications made under this except tritium and dissolved noble gases.

paragraph also satisfy the requirements of 920.2202 of this chapter.)"

$50,73(a)(2)(lx)

Reports submitted to the Commission in accordance with Datagraoh (a)(2)(viii) of this section also meet the effluent releasg reoortina requirements of 920.2203(a)(3) of tbisIhapleL If not reported under $50.72(a) or (b)(1), licensees are required to report such airborne or liquid effluent releases as defined in the regulations above to the NRC via the ENS as soon as practical and in all cases within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of the event. Licensees are required to submit an LER within 30 days.

die 9MASl00 i

Although similar to 10 CFR 20.403 (20.2202) and 20.405 (20.2203), these criteria place a lower threshold for reporting events at commercial power reactors because the significance of the breakdown of the licensee's program that allowed such a release is the primary concem, rather than the significance of the effect of the actual release.

1 For a release that takes less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , normalize the release to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (e.g., if the release i

lasted 15 minutes, divide by 4). For releases that lasted more than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , use the highest release for any continuous 60-minute period (i.e., comparable to a moving average).

NUREG 1022, Rev.1 84

Annual average meteorological data should be used for determining offsite airbome concentrations of radioactivity to maintain consistency with the technical specifications (TS) for reportability thresholds.

The location used as the point of release for calculation purposes should be determined using the expanded definition of an unrestricted area as specified in NUREG-0133 (" Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants," October 1978) to maintain consistency with the TS.

if estimates dotarmine that the release has exceeded the reporting criterion, an ENS notification 4

is required, followed up by a more precise estimate in the LER; if it is later determined that the release was less than this cruelion, the ENS notification may be retracted.

As indicated in Generic Letter 8519, September 27,1985, " Reporting Requirements on Primary Coolant lodine Spikes," vimary coolant iodine spike releases need not be reported on a short term basis.

Examoleg (1)

Unmonitored Release of Contaminated Steam Through Auxiliary Boiler Atmospheric Vent An unmonitored release of contaminated steam resulted from a combination of a tube leak, improper venting of an auxiliary boiler system, and inadequate procedures. This combination resulted in a release path from a liquid waste concentrator to the atmosphere via the auxiliary boiler system steam drum vent.

Because of rain at the site, the steam release to the atmosphere was condensed and deposited onto plant buildings and yard areas. This contamination was washed via a storm drain into a lake. The release was later confirmed to be 2.6 E 5 pCl/ml of Cs-137 at the point of entry into the receiving water.

An ENS notification is required as a liquid radioactive material release because the unmonitored release exceeded 20 times the applicable concentrations specified in Table 2, Column 2 of Appendix B to 10 CFR Part 20, averaged over 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at the site boundary. An LER is required.

(2)

Unplanned Gaseous Release During routine scheduled maintenance on a pressure actuated valve in the gaseous waste system, an unplanned radioactive release to the environment was detected by a main stack high radiation alarm. The release occurred when an isolation valve, required to be closed on the station tagout sheet, was inadvertently left open. This allowed radioactive gas from the waste gas decay tank to escape through a pressure gage connection that had been opened to vent the system. Operator error was the root cause of this release, with ambiguous valve tag numbers as a contributing factor. The 85 NUREG-1022, Rev.1 i

concentration in the unrestricted area, averaged over 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , was estimated by the l

licensee to be 1 E 5 pClimi of Kr-85 and 5 E4 pCi/ml of Xe 133.

The event was reportable via ENS and LER because the sum of the ratios of the concentration of each airborne radionuclide in the restricted area when averaged over a i

period of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , to Ms respective concentration specified in Table 2, Column 1 of Appendix B to 10 CFR 20, exceeds 20.

l i

I k

NUREG-1022, Rev.1 86

i 3.3.6 Contaminated Person Requiring Transport Offsite l

$50.72(b)(2)(v) 10 CFR 50,73 Licensees shall report: "Any event requiring

[No corresponding Part 50.73 requirement.]

the transpod of a radioactively contaminated persoa to an offsite medical facility for treatment."

If not reported under $50.72(a) or (b)(1), licensees are required to notify the NRC via the ENS of any such transport as soon as practical and in all cases within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of the event necessitating the offsite transport.

Discussion The phrase

radioactively contaminated" refers to either radioactively contaminated clothing and/or person, if there is a potential for contamination (e.g!, an initial onsite survey for radiosotive contamination is required but has not been completed befot9 transport of the person off site for medical treatment) the liconese should make an ENS _ notification. See the example.

No LER is required for transporting a radioactively contaminated person to an offsite medical facility for treatment.

Examole (1)

Radioactively Contaminated Person Transported Offsite for Medical Treatment A contract worker experienced a back injury lifting a tool while working in the reactor containment and was considered potentially contaminated because his back could not be riarveyed. Health physics (HP) technicians accompanied the worker to the hospital.

The licensee made an ENS notification immediately and an update notification after clothing, but not the individual, was found to be contaminated. The HP technicians returned to the plant with the contaminated protective clothing worn by the worker.

If not reported under $50.72(a)(1) as a declared Unusual Event per the licensee's emergency plan, an ENS notification is reqdmJ because of the transport of a radioactively contaminated person to an offsite medical facility for treatment.

i i

l 87 NUREG 1022, Rev.1

3.3.7 News Release or Other Government Notifications l

550.72(b)(2)(vi) 10 CFR 50.73 Licensees shall report: "Any event or

[No corresponding Part 50.73 requirement.)

situation, related to the health and safety of the public or on-site personnel, or protection of the environment, for which a news release is planned or notification to other government agencies has been or will be made. Such an event may include an on-site fatality or inadvertent release of radioactively contaminated materials."

If not reported under $50.72(a) or (b)(1), licensees are required to notify the NRC via the ENS as soon as practical and in all cases within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of the event, or the decision to prepare a news release, or the decision to notify (or actual notification of) other govemment agencies.

Rismission The purpose of this criterion is to ensure the NRC is made aware of issues that will cause heightened public or govemment concern related to the radiological health and safety of the public or on-site personnel or protection of the environment.

Licensees typically issue press releases or notify local, county, State or Federal agencies on a wide range of topics that are of interest to the general public. The NRC Operations Center does not need to be made aware of every press release made by a licensee. The following clanfications are intended to set a reporting threshold that ensures necessary reporting, while minimizing unnecessary reporting.

Examples of events likely to be reportable under this criterion include release of radioactively contaminated tools or equipment to public areas e

e unusual or abnormal releases of radioactive effluents e

onsite fatality Licensees generally do not have to report media and government interactions unless they are related to the radiological health and safety of the public or onsite personnel, or protection of the environment. For example, the NRC does no1 generally need to be informed under this criterion of:

minor deviations from sewage or chlorine effluent limits e

minor non-radioactive, onsite chemical spllis probiems with plant stack or water tower aviation lighting l

l NUREG-1022, Rev.1 88

peaceful demonstrations e

routine reports of effluent releases to other agencies ELC11EfdeAlf!

The NRC has an obligation to inform the public about issues within the NRC's purview that affect or raise a concern about the public health and safety. Thus, the NRC needs accurate, detailed information in a timely manner regarding such situations. The NRC should be aware of information that is available for the press or other government agencies.

However, the NRC need not be notified of every press release a licensee issues. The field of NRC interest is narrowed by the phrase "related to the health and safety of the public or onsite personnel, or protection of the environment,"in order to exclude administrative matters or those events of no safety significance.

Routine radiation releases are not specifically reportable under this e iterion. However, if a release receives media attention, the release is reportable under this criterion.

If possible, licensees should make an ENS notification before issuing a press release because news mecia representatives will usually contact the NRC public affairs officer shortly after its issuance for verification, explanation, or interpretation of the facts.

Other Government Notificationn For reporting purposes, "other government agencies" refers to local, State or other Federal agencies.

Notifying another Federal agency does not relieve the licensee of the requirement to report to the NRC.

For those plants which provide a State incident response facility with alarm indication coincident with control room alarms, e.g., an effluent radiation monitor alarm, but the actual radiation release is less than the criteria in 50.72(b)(2)(iv), the NRC does not consider these alarm indications as a notificat.on to the State by the licensee. An alaf 'eceived at a State facility is in itself not a requirement for notifying the NRC. In so far as this porting criterion 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.

Examoles (1)

Onsite Drowning Government Notifications and Press Release A boy fell into the discharge canal while fishing and failed to resurface. The licensee notified the tocal sheriff, State Police, U.S. Coast Guard and State emergency agencies.

Local news agencies were granted onsite access for coverage of the event. The licensee notified the NRC resident inspector.

89 NUREG-1022, Rev.1

As ENS notification is needed because of the fatality on site, the other government notifications made, and media involvement.

(2)

Licensee Media Inquiries f<egarding NRC Findings As a lesult of a local newspaper article regarding the findings of an NRC regional inspection of the 10 CFR Part 50, Appendix R, Fire Protection Program, a licensee representative was interviewed on local television and radio stations. The licensee notified State officials and the NRC resident inspector, The staff does not consider an ENS notification to be needed because the subject of the radio and Winterviews was an NRC inspection.

(3)

County Government Notification The licensee informed county governments and other organizations of a spurious actuation of several emergency response sirens in a county (for about 5 minutes according to county residents). The licensee also planned to issue a press release.

An ENS notification is needed because county agencies were notified regarding the inadvertent actuation of part of the public notification system. Such an event also would be reportable if the county informs the licensee of the problem because of the concern of the public for their radiological health and safety.

(4)

State Notification of Unscheduled Radiation Release The licensee reported to the State that they were going to release about 50 curies of gaseous radioactivity to the atmosphere while filling and venting the pressurizer, The licensee then revised their estimate of the release to 153 curies. However, since the licensee had not informed the State within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of making the release, they had to reclassify the release as " unscheduled" per their agreement with the State. The licensee notified the State and the NRC resident inspector, An ENS notification is needed because of the State notification of an " unscheduled" release of gaseous radioactivity. The initial notification to the State of the scheduled relears does not need an ENS notification because it is considered as a routine notification.

l (5)

State Notification of Improper Dumping of Radioactive Waste 1

The licensee transported two secondary side filters to the city dump as nonradioactive l

waste but later determined they were radioactive. The dump site was closed and the I

filters retrieved. The licensee notified the appropriate State agency and the NRC resident inspector.

i NUREG 1022, Rev,1 90

)

r An ENS notification is needed because of the notification to the State agency of the l

inadvertent release of radioactively contaminated material off site, which affects the radiological health and safety of the public and environment.

)

(6)

Reports Regarding Endangered Species The licensee notified the U.S. Fish & Wildlife Service and a State agency that an i

endangered species of sea turtle was found in their circulating water structure trash bar.

a No press release was issued.

An ENS nelltostion is regulrod boosuse of the nellboation of stato end federal egenotes foSeMilng Wie_taking of en endangered spooles. (The NRC has statuler f peopenetailleles i

regarding Pietection of,enden0ered species.)

l (7)

Routine Agency Notifications A licensee notified the U.S. Environmental Protection Agency (EPA) that the circulation water temperature rise exceeded the release permit allowable. This event was caused by the unexpected loss of a circulating water pump while operating at g2 percent power.

The licensee reduced power to 73 percent so that the circulating water temperature t

i would decrease to within the allowable limits until the pump could be repaired.

A licensee notified the Federal Aviation Agency that it removed part of its auxiliary boiler stack aviation lighting from service to replace a faulty relay.

A licensee notified the State, EPA, U.S. Coast Guard and Department of Transportation that 5 gallons of diesel fuel oil had spilled onto gravel-covered ground inside the protected area. The spill was cleaned up by removing the gravel and dirt.

The eleN does not consider en ENS notifloatior) to be needed boosues these events;are routine end have little signflicence.

4

-1 a

t 91 NUREG 1022, Rev.1

1 3.3.8 Spent Fuel Storage Cask Notifications 4

5 50.72(b)(2)(vil) 10 CFR 50.73 Licensees shall report: "Any instance of:

[No corresponding Part 50.73 requirement.)

(A) A defect in any spent fuel storage cask structure Pystem, or component which is important h safety; or (B) A significant reduction in the effectiveness of any spent fuel storage cask confinement system during use of the storage cask under a general license issued under 972.210 of this chapter.

A followup written report is required by

$72.216(b) of this chapter including a description of the means employed to repair any defects or damage and prevent i

recurrence, using instructions in $72.4, within 30 days of the report submitted in paragraph (a). A copy of the written report must be sent to the administrator of the appropriate Nuclear Regulatory Commission regional office shown in Appendix D to part 20 of this chapter."

If not reported under $50.72(a) or (b)(1), licensees are required to report any such instances to the NRC via the ENS as soon 6s practical, and in all cases within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . A followup written report is required by $72.216(b) within 30 days.

Discussion This information is necessary to inform the NRC of potential hazards to the public health and safety. The definition of " defect"in 10 CFR 21.3 is compatible with the intent of this reporting requirement. If the defect is evaluated and reported via this reporting criterion of $50.72, then as indicated in $21.2(c), the evaluation and notification obligations of 10 CFR Part 21 are met.

(See Section 5.1.9 for further discussion of Part 21 reporting.)

NUREG-1022, Rev.1 92 y_

3.4 Followup Notification This section addresses $50.72(c), Followup Notification." These notifications are in addition to making the required initial telephone notifications under $50.72(a) or (b). Reporting under this paragraph is intended to provide the NRC with timely notification when an event becomes more serious or additionalinformation or new analysis clarify an event. The paragraph also authorizes the NRC to maintain a continuous communications channel for acquiring necessary fullowup information.

$50.72(c) 10 CFR 50,73

" Followup Notification. With respect to the

[No corresponding Part 50.73 telephone notifications made under paragraphs (a) requirement.)

and (b) of this section, in addition to making the required initial notification, each licensee shall, during the course of the event:

(1)Immodiately reporf (i) any further degradation in the level of safety of the plant or other worsening plant conditions, including those that require the declaration of any of the Emergency Classes,if such a declaration has not been previously made, or (ii) any change from one Emergency Class to another, or (iii) a termination of the Emergency Class.

(2)Immediately reporf (i) the results of ensuing evaluations or assessments of plant conditions, (ii) the effectiveness of ritsponse or protective measures taken, and (iii) information related to plant behavior thn is not understood.

(3) Maintain an open, continuous communication channel with the NRC Operations Center upon request by the NRC."

Discussion These criteria are intended to provide the NRC with timely notification when an event becomes more serious or additional information or new analyses clarify an event. They also permit the NRC to maintain a continuous communications channel because of the need for continuing followup information or because of telecommunications problems.

With regard to the open, continuous communications channel, licensees have a responsibility to provide enough on-shift personnel, knowledgeable about plant operations and emergency plan implementation, to enable timely, accurate, and reliable reporting of operating events without 4

03 NUREG-1022, Rev.1

interfering with plant operation as discussed in the Statement of Considerations for the ru e and l

information Notice 85-80," Timely Declaration of an Emergency Class, implementation of an Emergency Plan, and Emergency Notifcations."

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i 4 EMERGENCY NOTIFICATION SYSTEM REPORTING This section describes the ENS referenced in 10 CFR 50.72 and provides general and specific guidelines for ENS reporting.-

4.1 Emergency Notification System The NRC Operations Center is the nucleus of the ENS and has the capability to handle emergency communication needs. The NRC's response to both emergencies and non-emergencies is coordinated in this communication center. The key NRC emergency communications personnel, the emergency officer (EO), regional duty officer (RDO), and the headquarters operations officer (HOO), are trained to notify appropriate NRC personnel and to focus appropriate NRC management attention on any significant event.

(1)

ENS Telephones Each commercial nuclear power reactor facility has ENS telephones funded by the NRC.

These telephones are located in each licensee's control room, technica! support center (TSC), and emargency operations facility (EOF). A separate ENS line is installed at EOF's which are not onsite. The ENS is pari of the Federal Telecommunications System (FTS). This FTS ENS replaces the dedicated ENS ringdown telephones used previously to provide a reliable communications pathway for event reporting.

(2)

Health Physics Network Telephones The health physics network (HPN) is designed to provide health physics and environmental information to the NRC Operations Centar in the event of an ongoing emergency.

These telephones are installed in each licensee's TSC and EOF and, like the ENS, they are now part of the FTS.

(3)

Tape Recording The NRC tape-records all conversations with the NRC Operations Center. The tape is saved for a month in case there is a public or private inquiry.

-(4)

Facsimile Transmission (Fax)

Licensees occasionally fax an event notification into the NRC Cperations Center on a commercial telephone line before making an ENS notification. However,650.72 95 NUREG-1022, Rev.1

requires that licensees notify the NRC Operations Center via the ENS; therefore, licensees also must make an ENS notification.

4.2 General ENS Notification 4.2.1 Timeliness The required timing for ENS reporting is spelled out in @S50.72(a)(3), (b)(1), (b)(2), (c)(1), (c)(2),

and in the Statements of Considerations, as "immediate" and "as soon as practical and in all cases within one (or four) hour (s)" of the occurrence of an event (depending on its significance).

The intent is to require licensees to make and act on reportability decisions in a timely manner so that ENS notifications are mada to the NRC as soon as practical, keeping in mind the safety of the plant. See Section 2.11 for further discussion of reporting timeliness.

4.2.2 Voluntary Notifications Licensees may make voluntary or courtesy ENS notifications about events or conditions in which the NRC may be interested. The NRC responds to any voluntary notification of an event or condition as its safety significance warrants, regardless of the licensee's classification of the reporting requirement. If it is determined later that the event is reportable, the licensee can change the ENS notification to a required notification under the appropriate 10 CFR 50.72 reporting criterion.

4.2.3 ENS Notification Retraction if a licensee makes a 10 CFR 50.72 ENS notification and later determines that the event or condition was not reportable, the licensee should call the NRC Operations Center on the ENS telephone to retract the notification and explain the rationale for that decision. There is no set time limit for ENS telephone retractions. However, since most retractions occur following completion of engineering and/or management review, it is expected that retrac' ions would occur shortly after such review. See section 2.10 for further discussion of retractions.

4.2.4 ENS Event Notification Worksheet (NRC Form 361)

The ENS Event Notification Worksheet (NRC Form 361) is an attachment to information Notice 89-89, dated December 26,1989, subject: Event Notification Worksheets. The worksheet provides the usual order of questions and discussion for easier communication and its use often enables a licensee to prepare amiwers for a more clear and complete notification. A clear ENS notification helps the HOO to understand the safety significance of the event.

Licensees may obtain an event number and notification time from the HOO when the ENS notification is made, if an LER is required, the licensee may include this information in the LER to provide a cross reference to the ENS notification, making the event easier to trace.

Licensees should use proper names for systems and components, as well as their alphanumeric identifications during ENS notifications. Licensees should avoid using local jargon for plant components, areas, operations, and the like so that the HOO can quickly NUREG-1022, Rev.1 96

understand the situation and have fewer questions, in addition, others not familiar with the plant can more readily unoerstand the situation.

4.3 Typical ENS Reporting issues At the time of an ENS notification, the NRC must independently assess the status of the reactor to determine if it is in a safe condition and expected to remain so. The HOO needs to understand the safety significance of aach event to brief NRC management or initiate an NRC response. The HOO will be primarily concemed about the safety significance of the event, the current condition of the plant, and the possible near term effects the event could have on plant safety. The HOO will attempt to obtain as complete a description as is available at the time of the notification of the event or condition, its causes, and its effects. Depending upon the licensee's description of the event, the HOO may be concerned about other related issues. The questions that the licensees typically may be asked to discuss do not represent a requirement for reporting. These questions are of a nature to allow the HOO information to more fully un'ferstand the event and its safety significance and are not meant in any way to distract the fict.nsee from more important issues.

The licensee's first responsibility during a transient is to stabilize the plant and keep it safe.

However, licensees should not delay declaring an emergency class when conditions warrant because delaying the declaration can defeat the appropriate response to an emergency.

Because of the safety significance of a declared emergency, time is of the essence. The NRC needs to become aware of the situation as soon as practical to activate the NRC Operations Center and the appropriate NRC regional incident response center, as necessary, and to notify other Federal agencies.

The effectiveness of the NRC response during an event depends largely on complete and accurate reporting from the licensee. During an emergency, the appropriate regional incident response center and the NRC Operations Center become focal points for NRC action.

Licensee actions during an emergency are monitored by the NRC to ensure that appropriate cetion is being taken to protect the health and safety of the public. When required, the NRC supports the licensee with technical analysis and coordinates logistics support. The NRC keeps other Federal agencies informed of the str.tus of an incident and pmvides informution to the media. In addition, the NRC assesses and, if necessary, confirms the appropriateness o; cetions recommended by the licensee to local and State authorities.

Information Notice 85-80, ' Timely Declaration of an Emergency Clars, Implementation of an Emergency Plan, and Emergency Notification," dated October 15,1985, indicates that it is the licensee's responsibility to ensure that adequate personnel, knowledge about plant cond'tions cnd emergency plan implementing procedures, are available on shift to assist the shift supervisor to classify an emergency and activate the emergency plan, including making appropriate notifications, without interfering with plant operation. When 10 CFR 50.72 was published, the NRC made clear its intent in the Statements of Consideration that notifications on the ENS to the NRC Operations Center should be made by those knowledgeable of the cvent. If the description of any emergency is to be sufficiently accurate and timely to meet the intent of the NRC's regulations, the personnel responsible for notification must be properly trained and sufficiently knowledgeable of the event to report it corre Jy. The NRC did not 97 NUREG-1022, Rev.1

intend that notifications made pursuant to 10 CFR 50.72 would be made by those who did not understand the event that they are reporting.

ENS reportability evaluations should be concluded and the ENS notification made as soon as practical and in all cases within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to meet 10 CFR 50.72. The Statement of Considerations noted that the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months deadline is necessary if the NRC is to fulfill its responsibilities during and following the most serious events occurring at operating nuclear power plants without interfering with the operator's ability to deal with an accident or transient in the first few critical minutes (48 FR 39041, August 29,1983).

4 NUREG 1022, Rev.1 98

-. -. =.. -....

f 5 LICENSEE EVENT REPORTS This section discusses the guidelines for preparing and submitting LERs. Section 5.1 addresses administrative requirements and provides guidelines for submittal, Section 5.2 i

addresses the requirements and guidelines for the LER conteril Portions of the rule are quoted, followed by explanation,if necessary. A copy of the required LER form (NRC Form 366), LER Text Continuation form (NRC Form 366A), and LER Failure Continuation form (NRC Forrn 3668), are shown at the end of this section. The use of LER information and the review programs associated with LERs are explained in Appendix C.

5.1 LER Reporting Guidelines This section addresses administrative requirements and provides guidelines for submittal.

Topics addressed include submission of reports, forwarding letters, cancellation of LERs, report legibility, reporting exemptions, reports other than LER4 that use LER forms, supplemental Information, revised reports, and general instructions for completing LER forms.

5.1.1 Submission of f ERs

$50.73(d)

" Licensee Event Reports must be prepared on Form NRC 366 and submitted within 30 days of discovery of a reportable event or situation to the U.S. Nuclear Regulatory Commission, as specified in $50.4."

An LER is to be submitted (mailed) within 30 days of the discovery date. If a 30-day period ends on a Saturday, Sunday, or holiday, reports submitted on the first working day following the end of the 30 days are acceptable. If a licensee knows that a report will be late or rweds an additional day or so to complete the report, the situation should be discussed with the appropriate NRC regional office. See Section 2.11 for further discussion of discovery date.

5.1.2 LER Forwarding Letter and Cancellations The cover letter forwarding an LER to the NRC should be signed by a responsible official.-

i There is no prescribed format for the letter. The date the letter is issued and the report date should be the same. Licensees are encouraged to include the NRC resident inspector and the i

institute of Nuclear Power Operations (INPO)in their distribution. Multiple LERs can be

]

forwarded by one forwarding letter, 99 NUREG-1022, Rev.1 o

Cancellations o LERs submitted should be made by letter.' The bases for the cancellatiori r

should be explained so that the staff can understand and review the reasons supporting the determination. The notice of cancellation will be filed and stored with the LER cod acknowledgement made in various automated data systems.

5.1.3 Report Legibility

$50.73(e)

"The repris and copies that licensees are required to r.ubmit to the Commisalon under the provisions of this section roust be of sufficient quality to permit legible reproduction and micrographic processing."

No further explanation is necessary.

5.1.4 Exemptions

$50.73(f)

"Upon written request from a licensee including adequate justification or at the initiation of the NRC staff, the NRC Executive Director for Operations may, by a letter to the licensee, grant exemptions to the reporting requirements under this section."

b Exemptions may be plant specific or generic. However, one of the goals of the LER rule is a consistent set of reporting requirements that apply to all plants. To minimize inconsistencies in the reporting, plant specific exemptions will not be issued unless Justified by unique plant conditioris.

5.1.5 Voluntary LERs Indicate information-type LERS (i.e., voluntary LERs) by checking the "Other" block in item 11 of the LER form and type " Voluntary Report"in the space immediately below the block. Also give a scauential LER number to the voluntary report as noted in Section 5.2.4(5). Because not all requirements of $50.73(b), " Contents," may pertain to some voluntary reports, licensees should develop the content of such reports to best present the information associated with the situation being reported.

See Section 2.9 for additional discussion of voluntary LERs.

j NUREG-1022, Rev.1 100

. _ _ _ _ _ _ _. _ _ ~ _ _

5.1.0 Supplemental Information and Revised LERs

$50.73(c)

"The Commission may require the licensee to submit specific additional information beyond that required by paragraph (b) of this section if the Commission finds that supplemental materialis necessary for complete understanding of any unusually complex or significant event. These requests for supp'emental information will be made in writir,9 and the licensee shall submit, as specified ir $50.4, the requested information as a supplement to th0 initial l

LER" This provision authorizes the NRC staff to require the licensee to submit specific supplemental information.

If an LER is incomplete at the time of original submittal or if it contains significant incorrect information of a technical nature, the licensee should use a revised report to provide the additional information or to correct technical errors discovered in the LER. Identify the revision to the original LER in the LER number as described in Section 5.2.4(5).

The revision should be complete and should not contain only supplementary or revised information to the previous LER because the revised LER will replace the previous report in the computer file. In addition, indicate in the text on the L2R form the revised or supplementary informs. tion by placing a vertical line in the margin.

If an LER mentions that an engineering study was being conducted, report the results of the study in a revised LER only it it would significantly change the reader's perception of the course, significance, implications, or consequences of the event or if it results in substantial changes in the corrective action planned by the licensee.

Use revisions only to provide additional or corrected information about a reported event. Do not use a revision to report subsequent failurcs of the same or like component, except as permitted in 10 CFR 50.73 Some licensees have incorrectly used revisions to report new events that were discovered months after the original event because they were loosely related to the original event. These revisions had different event dates and discussed new, although similar, events. Report events of this type as new LERs and not as revisions to previous LERs.

lf ; ;;e;%,for rep;OL; i i;;; ehech:d in ;;;.T.11 ;' NnO Terrn O end bt: lt vi;;

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T Vd.tri LCR b :: 7.0;d e.d it: it ;;;; :tir.. bed th;; ;he ;;;nt ;;;; requ;;;d to be i

iaW.ed, wt.T.;; e avt:d.LES b ;de,,;;;i ;h% %;L 5.1.7 Special Reports There are a number of requirements in various sections of the technical specifications that require reporting of operating experience that is not covered by 10 CFR 50.73. If LER forms 101 NUREG-1022, Rev.1

are used to submit special reports, check the "Other" block in item 11 of the form and type

Special Report",n the space immediately below the block. The provisions of 950.73(b) may not be applicable or appropriate in a special report. Develop the content of the report to best present the information associated with the situatio being reported. In addition, if the LER form is used to submit a special report, use a repun number from the sequence used for LERs.

if an event is reportable both under 10 CFR 50.73 and as a special report, check the block in ltem 11 for the applicable section of 50.73 as well as the "Other" block for a special report. The content of the report should depend on the reportable situation.

5.1.8 Appendix J Reports (Containment Leak Rate Test Reports)

A licensee must perform containment integrated and le illeak rate testing and report the results as required by Appendix J to 10 CFR Part 50. When the leak rate test identifies a 10 CFR 50.73 reportable situation (see Section 3.2.4 or 3.3.1 of this report), submit an LER and inclu s-the results in an Ap,sendix J report by reference, if desired. The LER should address only the reportable situation, not the entire leak rate test.

5.1.9 10 CFR Part 21 Reports 10 CFR Part 21, " Reporting of Defects and Noncompliance," as amended during 1o91, encourages licensees of operating nuclear power plants to reduce duplicate evalu.i an and reporting effort by evaluating deviations in basic components under the 10 CFR 50.72,50.73, and 73.71 reporting criteria. As indicated in 10 CFR 21.2(c) "For persons licensed to operate a nuclear power plant under Part 50 of this chapter, evaluation of potential defocts and appropriate reporting of defects under 99 50.72,50.73 or 73.71 of this chapter satisfies each person's evaluation, notification, and reporting obligation to report defects under this part. "As discussed in the Statement of Consideraiions for 10 CFR 21M, the only case where a defect in a basic component of an operating reactor might be reportable under Part 21, but not under 99 50.72,50.73, or 73.71 would involve Part(s) on the shelf. This type of defect, if it does not represent a condition reportable under 99 50.72 or 50.73, might still represent a condition reportable under 10 CFR Part 21.

l For an LFI rithe defect meets one of the criteria of 10 CFR 50.73, check the applicable paragraph in %m 11 of NRC Form 366 (LER Form). Licensees are also encouraged to check the "Other" block and indicate "Part 21" in the space immediately below if the defect in a basic component could create a substantial safety hazard. The wording in item 16 (" Abstract") and item 17 (" Text") shold state that the report constitutes a Part 21 notification. If the defect is h%cble.to other facilities at a multi-unit site; a single LER may be used by indicating the rathrovolved facilities in item 8 on the LER Form.

M 56 FR 36081, July 31,1991.

NUREG-1022, Rev.1 102

5.1.10 Sectic,n 73.71 Reports Submit events or conditions that are reponable under 10 CFR 73.71 using the LER forms with the appropriate blocks in item 11 checked. If the report contains safeguards information as defined in 10 CFR 73.21, the LER forms may still be used, but should be appropriately marked in accordance with 10 CFR 73.21. Include safeogards and security information on!v in the narrative and not in the abstract. In addition, the text should clearly indicate the information that is safeguards or security information. Finally, the requirements of $73.21(g) must be met when transmitting safeguards information. For adultfoal guidelines on 10 CFR 73.71 reporting, see Regulatory Guide 5.62, Revision 1. " Reporting of 5 afeguards Events," November 1987; NUREG-1304, " Reporting of Safeguards Events,"Abruary 1988; and, Generic Letter 91-03,

" Reporting of Safeguards Events," March t:l:3^A.

If the LER contains proprietary information, 'aark it appropriately in item 17 (text) on of the LER form. Include oroorittarv information only la the narrative and not in the abstract. In addition, indicate clearly in the narrative the information that is proprietary. Finally, the requirements of

$2.790(b) must be met when transmitting proprietary information, 5.1.11 Availability of LER Forms The NRC will provide LER forms (i.e., NRC Forms 366,366A, and 3668) free of charge.

Copies may be obtained by writing to the NRC Inforn ation and Records Management Branch, Office of the Chief Information Officer, US Nuclear Regulatory Commission, Washington, DC 20555. Electronic versions are also available. Licensees are encouraged to use these forms to assist the NRC's processing of the reports.

5.2 LER Content Requirements and Preparation Guidance Licensees are required to prepare an LER for those events or conditions that meet one or more of the criteria contained in $b0.73(a). Paragraph 50.73(b)," Contents," specifies the information that an LER should contain with further explanation when appropriate.

In 1988, the NRC decided to use an optical character reader (OCR) to read LER abstracts into NRC LER data bases (IE Information Notice No. 86-08, " Licensee Event Report (LER) Format Modification," February 3,1986). At that time, licensees were asked to help reduce the number of errors incurred by the OCR as a result of incompatible nrint styles by using OCR-compatible typography for preparing LERs. Therefore, certain limitations have been placed on the use of type styles and symbols for the abstract and text of the LERs. These limitations are listed below. (See the information Notice for details.)

Type Styles:

e Prestige Elite (12 pitch) e Letter Gothic (12 pitch)

OCR-B (12 pitch) e Courier 12 (12 pitch) e Elite (12 pitch) e 103 NUREG-1022, Rev.1

Courier 10 (10 pitch)

OCR-A (10 pitch) -

Prestige Pica (10 pitch)

In addition, the following proportional space type styles can be read: Madeleine, Cubic, Bold, and Title.

It is suggested that output be on typrwiter or formed character (letter-quality or near letter-quality) printer (e.g., daisy wheel, laer, ink Jet),

it is suggested that output have an uneven right margin (i.e., we suggest that you DQ1 right justify output).

It is suggested that text of the abstract be kept at least %-inch inside the border on all sides of the area designated for the abstract on the LER form. Text running into the border.can interfere with scanning the document, It is suggested that you do nol use underscore, do not use bold print, do not use Italic print style, do not end any lines with a hyphen and do not use paragraph indents. Instead, print copy single space with a blank line between paragraphs.

Limitations on the use of symbols in the textual areas:

Spell out the word " degree."

Use </= for "less than or equal to."

Use >/= for " greater than or equal to."

e Use +/- for "plus or minus."

Spell out all Greek letters.

Do not use exponents. A number should either be expressed as a decimal, spelled out, or preferably designated in terms of "E" (E field format). For example,4.2 x 104 could be expressed as 4.2E-6,0.0000042, or 4.2 x 10(-6).

Define all abbreviations and acronyms in both the_ text and the abstract and explain all component designators the first time they are used (e.gl; the emergency service _ water pumpc i i

SW-P-1A);

NUREG-1022, Rev.1 104 l

l

5.2.1 Narative Description or Text (NRC Form 366A, item 17) j (1)

General 550.73(b)(2)(i)

The LER shall contain: "A clear, specific, narrative description of what occurred so that knowledgeable readers conversant with the design of commercial nuclear power plants, but not familiar with the details of a particular plant, can understand the comp!ete event."

There is no prescribed format for the LER text; write the narrative in a format that most clearly describes the event. Nthough $50.73(b) deflne; the inferrn;tbn that 2.cutd b; includ;d, it is not intended ;a en cut;;ne v,,,~ _........ After the narrative is written, however, review the appropriate sections of $50.73(b) to make sure that applicable subjects have been adequately addressed. It is helpful to use headings to improve readability. For example, some LERs employ major headings such as event description, safety consequences, corrective actions, and previous similar events and subheadings such as bitial conditions, dates and times, event classification, systems status, event or condition causes, failure modes, method of disWary, component information, immediate corrective actbns, and actions to prevent recurrence.

Explain exactly what happened during the entire event or condition, including how systems, components, and operating personnel pe; formed. Do not cover specific hardware problems in excessive detail. Describe unique cha;acteristics of a plant as well as other characteristics that influenced the event (favorably or unfavorably). Avoid using plant-unique terms and abbreviations, or, as a minimu. clearly define them. The audience for LERs is large and does not necessarily know the details of each plant.

Include the root causes, the plant status before the event, and the sequence of occurrences.

Describe the event from the perspective of the operator (i.e., what the operator saw, did, perceived, understood, or misunderstood). Specific information that shculd be included, as appropriate, is described in paragraphs 50.73(b)(2)(ii), (b)(3), (b)(4), and (b)(5) of the rule and separately in the following sections.

If several engln;; red ;;f;ty f;;ture (EOF) systems actuate during an event, describe all aspects of the complete event, including all actuations sequentially, and those aspects that by themselves would not be reportable. For example, if a rendem-single component failure (generally not reportable) occurs following a reactor scram (reportable), describe the component failure in the narrative of the LER for the reactor scram. Th;rc l: n; n;cd to prev;d; redundent i.,;cimetbr, or unlmportent det;lls, but-it is necessary to discuss the performance and status of E6F equipment important for defining and understanding what happened and for determining the potentialimplications of'.he event.

l Paraphrase pertinent sections of the latest submitted safety analysis report (SAR) rather than referencing them because not all organizations or individuals hava access to SARs. Extensive cross-referencing would be excessively time consuming considef.ng the large number of LERs l

105 NUREG-1022, Rev.1 l

l

and large number of reviewers that read each LER. Ensure thet each applicable component's safety significant effect on the event or condition is clearly and completely described.

Do not use statements such as "this event is not significant with respect to the health and safety -

of the public" without explaining _the. basis for the. conclusion.

$50.73(b)(2)(lima) i The narrative description must include: " Plant operating conditions before the event."

Describe the plant operating conditions such as power level or, if not at power, describe mode, temperature, and pressure that existed before the event,

$50.73(b)(2)(il)(B)

The narrative description must include: " Status of structures, components, or systems that were inoperable at the start of the event and that contributed to the event."

If there were no structures, systems, or components that were inoperable at the start of the event and contributed to the event, so state. Otherwise; identify SSCs that were inoperable and contributed to the initiation or. limited the mitigation _ of the event tThis should include altomative mitigating SSCs that are a part of normal.or emergency _ operating procedures that were or could have. been used to mitigate, reduce the consequences of, or limit the safety implications of the. event.; include the impact of support systems _on mitigating systems that could have been.used,

$50.73(b)(2)(ll)(C)

The narrative description must include: " Dates and approximate times of occurrences."

For a transient or ESF actuation event, the event date and time are the date and time the event actually occurred. If the event is a discovered condition for which the occurrence date is not known, the event date should be specified as the discovery date. However, a discussion of the best estimate of the event date and its basis should be provided in the narrative. For example,

-l

= if a design deficiency was identified on March 27,1997 that involved a component installed during refueling in the spring of 1986, and only the discovery date is known with certainty, the event date should be specified as the discovery date.- A discussion should be provided that describes, based on the best information available, the most likely time that the design flaw was introduced into the component (e.g, by manufacturer or by plant engineering prior to procurement).- The. length of time that the component was in service should also be provided (1:e ;,when it was installed)i NUREG-1022,- Rev.1 106 3- -.,,.~...

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Discuss both the discovery date and the event date if they differ. If an LER is not submitted within 30 days from the event date, explain the relationship between the event date, discovery date, and report date in the narrative. See Section 2.11 for further discussion of discovery date.

Give dates and aooroximate times for all major occurrences discussed in the LER (e.g.,

discoveries; immediate corrective actions; systems, components, or trains declared inoperable i

or operable; reactor trip; actuation and termination of equipment operation; and stable conditions achieved).' in particula _r, for_ standby pumps ~ and emorponcy generators, indicate the length of time of operation and any intermittent periods.cf shutdown or.inoperability during the event include an estimate of the time and date of failure of systems, components, or trains if a

different from the time and date of discovery. A chronology may be.uosd.to. clarify the tumng of l

personnel _ and equipment actions; i'

For equipment that was inoperable at the start chhe eventc provide'an estimate.of the time the equipment becsme inoperable and the last time the equipment was known to be operable.;

indicale the basis for this conclusion (e.g.,' a test was successfully,run'or the equipment was operating):3 For equipment that failed; provide the failure time and the last time the _ equipment was known.to be operable:fAlso provide the basis forthe_last time known operable; Components such as valves and snubbers may be tested over a period of several weeks.

During this period, a number of inoperable similar components may be discovered.M In such cases, similar failures that are reportable and that are discovered during a single test program within the 30 davs of discovery of the first failure may be reported as one LER. For similar.

failures that are reportable under Section 50.73 criteria and that are discovered during a single test program or activity, report all failures that occurred within the first 30 days of discovery of the first failure on one LER. However, the 30-day clock starts when the first reportable event is discovered. State in the LER text (and code the information in items 14 and 15) that a supplement to the LER will be submitted when the test is completed. Submit a revision to the original LER when the test is completed, include all the failures, including those reported in the original LER, in the revised LER (i.e., the revised LER should stand alone).

(3)

Failures and Errors i

$50.73(b)(2)(ll)(D)

The narrative descr ption must include: "The cause of each component or system failure or personnel error, if known."

include the root cause(s) identified for each oom. ponent or. system _ failure (or fault) orpersontml error 6Contdbuting factors may be docussed as'appropnated For_ example, a valve stern M-Note that inoperable similar components might indicate common cause failures of :

_ independent trains or channels, which are reportable under $50.73(a)(2)(vii); see Section 3.3.4 h

for further discussion.

107 NUREG-1022, Rev.1

~

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tweeking couw have been,oeused by a limit switch that had been improperty adposed during mounenenos; in this osse, the root cause_might to determined to be personnel error and edemonal dienuosion oouw focus.on_the limit switch adjustment.; if the personnel.orror.is determined to have been caused by dencient procedures or inadequate personnel training,Lthis should be expisined, -

If the oeuse of a failure cannot be rossly determined and thernC":-, is continuing, the LER should indioses what additional _Irwestigalion is planned. A supplemental LER_ should be submmed sollowing the edstional investigation if substantial information is identified that would signmoently change a reader's perception of the course or consequences of the. event;or if 1

there are substantial changes in the corrective actions planned by the licensee!

$60.73(b)(2)(li)(E)

The narrative description must include: "The failure mode, mechanism, and effect of each failed component, if known."

include the failure mode, mechanism (immediate cause) Land effect of each failed _ component in the narrative.tThe effect of the, failure on safety systems and functions should be fully described, identify the specillo piece part that falsed and the specific trains.and systems rendered inoperable or degradedaldentify all dependent systems rendered inoperable or degraded. Indioste whether redundant trains were operable and available, if the equipment is dograded, but. ot failed, describe the. degradation and its effoots.and n

indioste why the. equipment would still perform its_ intended function, 560.73(b)(2)(ll)(F)

The narrative description must include: "The Energy industry identification System component function identifier and system name of each component er system referred to in the LER.

(1) The Energy industry identification System is defined in: IEEE Std 803-1983 (May 16, 1983) Recommended Practice for Unique identification in Power Plants and Related Facilities-Principles and Definitions.

(2) IEEE Std 803-1983 has been approved for incorporation by reference by the Director of the Federal Register.

A notice of any changes made to the material incorporated by reference will be published in the FederalRegister. Copies may be obtained from the Institute of Electrical and Electronics Engineers,345 East 47th Street, New York, NY 10017. IEEE Std 803-1983 is available for inspection at the NRC's Technical Library, which is located in the Phillips (Continued on next page)

NUREG-1022, Rev.1 108 I

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550.73(b)(2)(ll)(F) (Continued)

Building,7920 Norfolk Avenue, Bethesda, Maryland; and at the Office of the Federal Register,1100 L Street, NW, Washington, DC."

Note:LThe NRC library is now located in the Two White Flint North buildingc 11545 Rockville Pike, Rockville, Maryland.

The system name may tse either the full name (e.g., reactor coolant system) or the two-letter system code (such as AB for the reactor coolam system). However, when the name is long (e.g., low-pressure coolant injection system), the system code (e.g., BO) should be used, if the full names are used, The Energy Industry identification System (Ells) component function identifier and/or system identifier (i.e., the two letter code) should be included in parentheses following the first reference to a component or system in the narrative. The component function identifiers and system identifiers need not be repeated wnh each subsequent reference to the same component or system.

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b^4;Fidbre eer"; bed b 04 N"",OS ":;-:-nt': 0;__q;r.d 0;7c.prer; C4:-p M;2'? ' jf a component within the scope of the Equipment Performance end Information Exchange (EPIX)

System is involved, the system and train designation.should be consistent with the Ells used in

EPIX, 550.73(b)(2)(ii)(G)

The narrative description must include the following specific information as appropriate for the particular event: "For failures of components with multiple functions, include a list of systems oc secondary functions that were also affecteo."

No further explanation is necessary.

$50.73(b)(2)(ll)(H)

The narrative description must include: "For failure that rendered a train of a safety system inoperable, an estimate of the elapsed time from the discovery of the failure until the train was returned to service."

No further explanation is necessary, 109 NUREG-1022, Rev.1

$50.73(b)(2)(ii)(l)

The narrative description must include: "The method of oiscovery of each component or system failure or procedural error."

Explain how each component failure, system failure, personnel error, or procedural deficiency was discovered. Examples include reviewing surveillance procedures or results of surveillance tests, pre-startup valve lineup check, performing quarterly maintenance, plant walkdown, etc.

$50.73(b)(2){li)(J)

The narrative description must include the following specific information as appropriate for the particular event:

"(1) Operator actions that affected the course of the event, including operator errors, procedural deficiencies, or both, that contributed to the event.

(2) For each personnel error, the licensee shall discuss:

(i) Whether the error was a cognitive error (e.g., failure to recognize the actual plant condition, failure to realize which systems should be functioning, failure to recognize the true nature of the event) or a procedural error; (ii) Whether the error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated with an activity or task that was not covered by an approved procedure; (iii) Any unusual characteristics of the work location (e.g., heat, noise) that directly contributed to the error; and (iv) The type of personnel involved (i.e., contractor personnel, utility-licensed operator, utility non-licensed operator, other utility personnel)."

Human performance often influences the outcome of nuclear power plant events. Human error is known to contribute to more than half of the LERs. The LER rule identifies the types of reactor events and problems that are believed to be significant and useful to the NRC in its erfort to identify and resolve threats to public safety. It is designed to provide the information necessary for engineer'ng studies of operational anomalies and trends and patterns analysis of operational occurrences including human performance.

Generally, the criteria of Section 50.73(b)(2)(l) require a clear, specific narrative so that knowledgeable readers can understand the complete event. Further, the criteria of Section 50.73(b)(2)(ii)(J) require a description of (1) operator actions that affected the coursa of the event and (2) for each personnel error, additional specific information as detailed in the rule. In order to support an understanding of human performance issues related to the event, address the factors discussed below to the extent they apply,. For example, if an operator error that affected the course of the event was due to a procedural problem, indicate the_ nature of the procedural problem such as missing procedure, procedure inadequate due to technical deficiencv, etc.

1 NUREG-1022, Rev.1 110

l l

Personnel errors and human performance related issues may be in_the areas. of procedures; training, communication, human engineeringi managementi and supervision:c For example, in i

the _ arse of procedures, enors might be_. due to missing procedures, procedures _which are inadequate due to_ technical or human factors danciencies,.or which have not been maintained current llIn the_ area of training, errors _may_be the result of a failure to provide training; having

)

provided inadequate training, or as the result of traming (such as simulator training or on-the-job -

i training) that does not provide an environment comparable to_that in the plant.

communiostions errors may be due to inadequate, untunely. misunderstood l.or missmo communiostion or due to the quality _of the communication equipment. Human engineering leeues include those related to the interface or lack thereof between the human and the i

rnachine (such as size, shape, location, function or content of displays, nontrois, equipment or labels) as well as; environmental house such as lighting, temperature l noise, redation and worl(

i

. ares layout 4 Management errors meght be.due to, management expectations, corrective actions, root cause determinations, or audits which are inadequate, untimely or missing ain the area of l

supervleion, errors.may be the result of a lack _of supervision, inadequate supervision, job

(

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stalling, overtimei scheduling and planning l work practices (such as briefingsilogs, work packages, team work, decision making, and housekeeping).or.because of inadequate i

vertlication, awareness or self-checkinga i

4 360.73(b)(2)(li)(K)

The narrative description must include: " Automatically and manually initiated safety system i

responses." -

i The LER should include a. discussion of each spoolfic system that actuated _or failed to actuate.i Do.not limit the discussion to ESFac indicate,the specific equipment that actuated or should

- have actuated, by train,; compatible with EPIX train. definitions (e.gc, auxiliary.feedwater train B).;

i indicate whether or not.the equipment operated successfully; 4

2 560,73(b)(2)(ii)(L)

The narrative description must include: "The manufacturer and model number (or other identification) of each component that failed during the event."

The manufacturer and model number (or othe_r identification, such as type; sizefor manufacture

- date) also..should be given for,each component found failed. during the course of,the event $n example of other identification could.be (for a pipe rupture) size, schedulei;or_ material composition; 4

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111-NUREG-1022, Rev.1 -

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Auenment of Safety Conse.Quentes

$50.73(b)(3)

The LER shall contain: "An assessment of the safety consequences and implications of the event. This assessment must include the availability of other systems or components that could have performed the same function as the components and systems that failed during the event."

Give a summary assessment of the actual and potential safety consequences and implications of the event, including the basis for submitting the report. Evaluate the event to the extent necessary to fully assess the safety consequences and safety margins associated with the event.

Include an assessment of the event under attemative conditions if the incident would have been more severe (e.g., the plant would have been in a condition not analyzed in its latest SAR) under reasonable and credible attemative conditions, such as a different operating mode. For example, if an event occurred while the plant was at low power and the same event could have occurred at full power, which would have resulted in considerably more serious consequences, this alternative condition should be assessed and the consequences reported.

Reasonable and credible attemative conditions may include normal plant operating conditions, potential accident conditions, or additional component failures, depending on the event. Normal attemative operating conditions and off-normal conditions expected to occur during the life of the plant should be considered. The intent of this section is to obtain the result of the considerations that are typical in the conduct of routine operations, such as event reviews, not to require extraordinary studies.

(4)

Corrective Actions

$50.73(b)(4)

The LER shall contain: "A description of any corrective actions planned as a result of the event, including those to reduce the probability of similar events occurring in the future."

Include whether the corrective action was or is planned to be implemented. Discuss repair or replacement actions as well as actions that will reduce the probability of a similar event occurring in tha future. For example, "the pump was repaired and a discussion of the. event Was included Iri the training lectures."; Another example, "although no rnodification to the instrument.was deemed necessary, a caution note was placed in the calibration procedure for the instrument before the step in which the event was initiated."

NUREG-1022, Rev.1 112

In addition to a description of any corrective actions planned as a result of the event, describe corrective actions on similar or related components that were done, or are planned, as a direct result of the event. For example,if pump 1 failed during an event and required corrective maintenance and that same maintenance also was done on pump 2, so state.

If a stud / was conducted, and results are not available within the 30-day period, report the results of the study in a revised LER if they result in substantial changes in the corrective action planned. (See Section 5.1.6 for further discussion of submitting revised LERs.)

(5)

Previous Occurrences

$50.73(b)(5)

The LER shall contain: " Reference to any previous similar events at the same plant that are known to the licensee."

The term " previous occurrences" should include previous events or conditions that involved the same underlying concern or reason as this event, such as the same root cause, failure, or sequence of events. For infrequent events such as fires, a rather broad interpretation should be used (e.g., all fires and, certainly, all fires in the same building should be considered previous occurrences). For more frequent events such as ESF actuations, a narrower definition may be used (e.g., only those scrams with the same root cause). The intent of the rule is to identify generic or recurring problems.

The licensee should use engineering judgment to decide how far back in time to go to present a reasonably complete picture of the current problem. The intent is to be.able to see a pattern in recurring events, rather than to get a complete 10- or 20-year history of the systemi If the event was a high-frequency type of event,2 years back may_be more than sufficient.;

include the LER number (s), if any, of previous similar events. Previous sim_ilar events are not necessarily limited to events reported in LERs; If no previous similar events are known, so state. If any earlier events, !.t retrospect, were significant in relation to the subject event, discuss why prior corrective action did not prevent recurrence.

(6)

LER Text Continuation Sheet (NRC Form 366A)

Use one or more additional text continuation sheets of the LER Form 366A to continue the narrative, if necessary. There is no limit on the number of continuation sheets that may be included.

Drawings, figures, tables, photographs, and other aids may be included with the narrative to help readers understand the event. If possible, provide the aids on the LER form (i.e., NRC Form 366A). In addition, care should be taken to ensure that drawings and photographs are of sufficient quality to permit legible reproduction and micrographic processing. Avoid oversized drawings (i.e., larger than 8 % x 11).

113 NUREG-1022, Rev.1

5.2.2 Abstract (NRC Form 366, item 16) d i

$50.73(b)(1)

The LER shall contain: "A brief abstract describing the major occurrences during the event,

, including all component or system failures that contributed to the event and significant corrective action taken or planned to prevent recurrence."

i Provicie a brief abst act describing the major occurrences during the event, including all actual component or system fa' lures that contributed to the event, all relevant operator errors or violations of procedures, the root cause(s) of the major occurrence (s), and the corrective action taken or planned for each root cause. If space does not permit describing failures, at least indicate whether or not failures occurred. Limit the abstract to 1400 characters (including spaces), which is approximately 15 lines of single spaced typewritten text. Do not use Ells component function identifiers or the two-letter codes for system names in the abstract.

lt b ;w;pt;b'; to C;;i;te th; ent:re ; vent in th; ;bti;;t ep;;;. l bv;;;;;, M dsedp;bn ;f th; ;va; ;hedd M n",; bat ly de;;;bd ec Mt ; bev;bds;;bb.inder ;;n underdend thc

pit; ; vent. F;;; cep;ct;bb cvent; ve"l b; ;; ;bpSib th;t they ;;n M ;Cqu;;;'y ds dMd ln 1400 ch;;;;;;;;.

The abstract is generally included in the LER data base to give users a brief description of the event to identify events of interest. Therefore, if space permits, provide the numbers of other LERs that reference similar events in the abstract.

As noted in Section 5.1.10, do not include safeauards. security. or oroorictarv information in the abstract.

5.2.3 Other Fields on the LER Form (1)

Facility Name (NRC Form 366. Item 1)

Enter the name of the fac;iity (e g., Indian Point, Unit 1) at which the event occurred. If the event involved more than one unit at a station, enter the name of the nuclear facility with the lowest nuclear unit number (e.g., Three Mile Island, Unit 1).

(2)

Docket Number (NRC Form 366. Item 2)

Enter the docket number (in 8-digit format) assigned to the unit. For example, the docket number for Yankee-Rowe is 05000029. Note the use of zeros in this example.

(3)

Pace Number (NRC Form 366 Item 3)

Enter the total number of pages included (including figures and tables that are attached to item 17 Text) in the LER package. For continuation sheets, number the pages consecutively NUREG-1022, Rev.1 114

)

beginning with page 2. The LER form, including the abstract and other data is pre-numbered on the form as page 1 of.

I (4)

Title (NRC Form 366. Item 4)-

The title should include a concise description of the principal problem or leeue maaam with the event, the root cause, the result (why the event was required to be reported), and the link -

between them, if poselbloJit is oben easier to form _ the title after. writing the asessement c(the event beoeuse the information le clearly et hand!

" Licensee Event Report" should 091 be used as a title. The. title " Reactor Trip"is considered inadequate, boomune the root cause and the. link between the root cause_ and the result are missing.1The title," Personnel Error.Causes Reactor; Trip" is considered irWe because of 4

the innumerable ways in which a person could cause a_ reactor trip.N" Technician inadvertently tr$ected Signal Resulting in a Reactor, Trip".would be a better title,

~(5)

Event Date (NRC Form 366. Item 5)

Enter the date on which the event occurred in the eight spaces provided. There are two spaces for the month, two for the day, and four for the year, in that order. Use leading zeros in the first and third spaces when appropriate. For example, June 1,1987, would be properly entered as 0601.1987.

If the date on which the event occurred cannot be clearly defined, use the discovery date. See i

Section 2.11 of this report for further discussion of discovery date.

(6)

Report Number (NRC Form 366. Item 6) f The LER number consists of three parts: (a) the four digits of the event year (based on event date), (b) the sequential report number, and (c) a revision number. The numbering system is shown in the diagram below; the event occurred in the year 1991, it was the 45th event of that year, and the submittal was the 1st revision to the original LER for that event.

Event Sequential Revision yJtAI Reoort Number Number 01 045

,1991 Event Year: Enter the four digits. The event year should be based on the event date (Item 4).

Seouential Reoort Number: As each reportable event is reported for a unit during the year, it is assigned a sequential number. For example, for the 15th and 33rd events to be reported in a given year at a given unit, enter 015 and 033, respectively, in the spaces provided. Follow the 9

guidelines below to ensure consistency in the sequential numbering of reports, Each unit should have its own set of sequential report numbers. Units at multi-unit sites e-should 001 share a set of sequential report numbers.

115 NUREG-1022, Rev.1 i

-I

l l

The sequential number should begin with 001 for the first event that occurred in each calendar year, using leading zeros for sequential numbers less than 100.

For an event common to all units of a multi-unit site, assign the sequential number to the e

lowest numbered nuclear unit.

if a sequential number was assigned to an event, and it was subsequently determined e

that the event was not reportable, a " hole"in the series of LER numbers would result.

The NRC would prefer that licensees reuse a sequential number rather than leave holes in the sequence. A sequential LER number may be reused even if the event date was later than subsequent reports.

If the licensee chooses not to reuse the number, write a bnef letter to the NRC noting that "LER number xxx for docket 05000XXX will not be used."

revision Number: The revision number of the original LER submitted is 00. The revision number for the first revision submitted should be 01. Subsequent revisions should be numbered sequentially (i.e., 02,03,04).

(7)

Reoort Date (NRC Form 366. Item 7)

Enter the date the LER is submitted to the NRC in the eight spaces provided, as described in j

Section 5.2.4(4) above.

(8)

Other Facilities (NRC Form 366. Item 8)

When a situation is discovered at one unit of a facility that applies to more than the one unit, submit a single LER. LER form items 1,2,6,9, and 10 should refer to the unit primarily affected, or, if both units were affected approximately equally, to the lowest numbered nuclear unit.

The intent of the requirement is to name the facility in which the primary event occurred, whether or not that facility is the lowest numbered of the facilities involved. The automatic use of the lowest number should only apply to cases where both units are affected approximately equally. Item 0 only should indicate the other unit (s) affected. The abstract and the text should describe how the event affected ali units.

Enter the facility name and unit number and docket number (see Sections 5.2.4(1) and 5.2.4(2) for format) of any other units at that site that were directly affected by the event (e.g., the event included shared components, the LER described a tomado that threatened both units of a two-unit plant).

(9)

Ooeratino Mode (NRC Form 366. Item 9)

Enter the operating mode of the unit at the time of the event as defined in the plant's technical specifications in the single space provided. For plants that have operating modes such as hot NUREG-1022, Rev.1 116

1 1

i shutdown, cold shutdown, and operating, but do not have numerical operating modes (e.g.,

Mode 5), place the letter N in item 9 and describs the operating mode in the text.

(10)

Power Level (NRC Form 366. Item 10)

Enter the percent of licensed thermal power at which the "eactor was operating when the event occurred. For shutdown conditions, enter 000. For all other operating conditions, enter the correct numerical value (estimate power level if it is not known precisely), using leading zeros as appropriate (e.g.,009 for 9 percent power). Significant deviations in the operating power in the balance of plant should be clarified in the text.

(11)

Reoortina Reauirements (NRC Form._366. Item 11)

Check one or more blocks according to the reporting requirements that apply to the event. A single event can meet more than one reporting criterion. For example: if as a result of sabotage, reportable under $73.71(b), a safety system failed to inction, reportable under

$50.73(a)(2)(v), and the net result was a release of radioactive n, sterial in a restricted area that exceeded the applicable license limit, reportable under @20.2203(a)(3)(i), prepare a single LER and check the three boxes for paragraphs 73.71(b),50.73(a)(2)(v), and 20.2203(a)(3)(i).

In addition, an event can be reportable as an LER even if it does not meet any of the criteria of 10 CFR 50.73. For example, a case of attempted sabotage (673.71(b)) that does Dat result in any consequences that meet the criteria in 50.73 can be reported using the "Other" block. Use the "Other" block if a reporting requirement other than those specified in item 11 was met.

Specifically describe this other reporting requirement in the space provided below the "Other" block and in the abstract and text.

(12)

Licensee Contact (NRC Form 366. Item 12) 950.73(b)(6)

The LER shall contain: "The name and telephone number of a person within the licensee's organization who is knowledgeable about the event and can provide additional information concerning the event and the plant's characteristics."

Enter the name, position title, and work telephone number (including area code) of a person who can provide additional information and clarification for the event described in the LER.

(13)

Comoonent Failures (NRC Form 366. Item 13)

Enter the appropriate data for each component failure described in the event.

A failure is defined as the termination of the abili*y of a component to perform its required function. Unannounced failures are not detected until the next test; announced failures are detected by any number vf methods at the instant of occurrence.

117 NUREG-1022, Rev. I

If multiple components of the same type failed and all of the information required in item 13 (i.e., cause, system, component, etc.) was the same for each component, then only a single entry is required in item 13. Clearly define the number of components that failed in the abstract and text.

The component information elements of this item are discussed below.

Cause Enter the cause code as shown below, if more than one cause code is applicable, enter the cause code that most closely describes the root cause of the failure.

i Cause Code Classification and Definition A

Personnel Error is assigned to failures attributed to human errors. Classify errors made because written procedures were not followed or because personnel did not perform in accordance with accepted or approved practice as personnel errors. Do not include errors made as a result of following incorrect written procedures in this classification.

B pesian. Manufacturina Construction / Installation is assigned to failures reasonably attributed to design, manufacture, construction, or installation of a system, component, or structure. For example, include failures that were traced to defective materials or components otherwise unab!e to meet the specified functional requirements or performance specifications in this classification.

C Extemal Cause is assigned to failures attributed to natural phenomena. A typical example would be a failure resulting from a lightning strike, tomado, or flood.

Also assign this classification to man-made extemal causes that originate off site (e.g., an industW accident at a nearby industrial facility).

D Defective Proceduwe assigned to failures caused by inadequate or incomplete written procedures or instructions.

E Manaoement/Ouality Assurance Deficiency is assigned to failures caused by inadequate management oversight or management systems (e.g., major breakdowns in the licensee's administrative controls, preventive maintenance program, surveillance program, or quality assurance controls, inadequate root cause determination, inadequate corrective action).

X Other is assigned to failures for which the proximate cause cannot be identified or which cannot be assigned to one of the other classifications.

System: Enter the two-letter system code from Institute of Electrical and Electronics Engineers (IEEE) Standard 805-1984, "lEEE Recommended Practice for System Identification in Nuclear Power Plants and Related Facilities," March 27,1984. Copies may be obtained from the Institute of Electrical and Electronics Engineers,345 East 47th Street, New York, NY 10017.

NUREG-1022, Rev.1 118

Comoonent: Enter the applicable component code from IEEE Standard 803A-1983, "lEEE Recommended Practice for Unique Identification in Power Plants and Re:eted Facilities - Component Function Identifiers."

Comoonent Mer.ofacturer: Enter the four character alphanumeric reference code. 074; 'O d O 7:^^O0 ".:;- O.;; C:M::a; !':7.;;! d:::::':::.e;i:

-4:::: ; e,T.;2:ted :.2 4ICard;1.g -:-:-t;.Ta:7.t: red ;, !;^3's

e.T.;2:1 C:::,y 2.T.;r._' is; t..;t a; r.;' b-if:I b. L #;' c; ."^^., lf the manufacturer lione used ir? EPIX / use the manufacturer name as it appears in EPIX; Reoortable to EPE: Enter a "Y"if the failure is reportable to ER, and an "N"if it is not reportable.

Include in the LER text and in item 13 of the LER Form any component failure involved in the event, not just components within the scope of EPIX or Ells.

Failure Continuation Sheet (NRC Form 3668): If more than four failures need to be coded, use one or more of the failure continuation sheets (NRC Form 366B).

Code the entries in items 1,2,3, and 6 of the failure continuation sheet to match entries of these items on the initial page of the LER. Complete item 13 in the same manner as item 13 on the basic LER form. Do not repeat failures coded on the basic LER form on the failure continuation sheet. Place any failure continuation sheets after any text continuation sheets and include those sheets in the total number of pages for the LER.

(14)

Sucolemental Report (NRC Form 366. Item 14)

Check the "Yes" block if the licensee plans to submit a followup report. For example, if a failed component had been returned to the manufacturer for additional testing and the results of the test were not yet available when the LER was submitted, a followup report would be submitted.

(15)

Exoected Submission Date of Sucolemental Reoort (NRC Form 366. Item 15)

Enter the expected date of submission of the supplemental LER,if applicable. See Section 5.2.4(4) for the proper date format. The expected submission date is a. target / planning _date; it is not a regulatory commitmentJ 119 NUREG-1022, Rev.1

NRC FORM 344 U.S. NUCLEAR REOULATORY COMMIS$10N APPROVED BY OMS NO. 31604104 EXPIRES MM/DD/YYYY (MM-YYYY)

Eshmeted tiurden per oeponse to comp 4 unth this mandatory Irwormation conectionrequest E0 rro Reportediescons teemed are inwrporoled into the LICENSEE EVENT REPORT (LER) tourden eeTio7E NC$P * ""*"*areJ' F33).O $ NuclearReg Commesson. Wet 20555-0001 and lo the P Reduction (3150-0104).

of Management and (See reverse for to4uirad number of

sudget, oc 20503 r a document used m ampose an rwormaton digits / characters for each block) comecean does not despier a curroney veho oms control number, the NRC may not conducs or sponsor, and a person is not required to roepond to, tne musa as FACluTY NAA4E (1)

DOCKET nut 40ER (2)

PAGE (3) 05000 1 OF trns ses EVEldT DA TE (61 LFR NUMBER lill REPORT DATE (7)

OTHER FACILITIES IdVOLVED (8)

F ACILITY NAME DOCKET NUMetR II U

'^L

$ N MONTH DAY YEAR YEAR MONTH DAY YEAR NU CR NU B F ACILfTV NAME DocuET NUMe(A I

OPERATING THIS REPORT IS SUBM TTFD PURSUANT TO THE REQLilREMENTS OF 10 Crh'It (Check one or more) (11)

MODE (9) 20.2201(b) 20.2203(aH2)(vl 60,73(a)(2)h) 60.73(a)(2)(viii) r POWER 20.2203(aH1) 20.2203(aH3)h) 60.73(a)(2)hi) 60.73(a)(2H z)

LEVEL (10) 20.2203(aH2)D) 20.2203(as(3)Dil 60.73(a)(2) Dei) 73.71 20.2203(aH2) Del 20.2203(aH41 60.73(aH2)(ev)

OTHER

, +-

p ll 1 20.2203(a)(2)(m) 60.36(c)(1) 60.73(aH2)(v) speciry in Adetreet tasow e*

s 20.2203(aH210v) 60.36(cH2) 60.73(aH2Hvii) or en NRC Form 366A LICENSEE CONTACT FOR THIS LER (121 NAWE f tLEPHONE NUMetR linclude Atee Codel COMPLETF ONE LINE FOR E ACH COMPONEldT FAILURE DEECRMED IN THIS REPORT i13)

[

CAUSE SYSTEM COMPONENT MANUFACTURER RE RTABLE NI CAUGE SYSTEM COMPONENT MANUFACTURER T E T

9 u

4

.a SUPPLEMENTAL REPORT EXPECTED (14)

MONm DAY YEAR EXPECTED YES SUBMISSION NO (if y:s, complete EXPECTED SUBMISSION DATE),

DATE (16)

ABSTRACT (Limit to 1400 spaces. 4.e., approximately 16 single-spaced typewritten lines) (161 I

t l

NUREG-1022, Rev.1 120 NRC PORM 306 iMM YYYT)

REQUIRED NUMBER OF DIGITS / CHARACTERS FOR EACH BLOCK BLOCK NUMSER OF TIT NUMSER DIGITS / CHARACTERS 1

UP TO 46 FACILITY NAME DOCKET NUMBER 2

3 IN ADDITI TO 05000 3

VARIES PAGE NUMBER 4

UP TO 76 TITLE 8 TOT AL 2

M m EVENT DATE 6

p y

4 FOR YEAR 9 TOTAL 4FOR YEAR LER NUMBER 6

3 FOR SEQUENTIAL NUMBER 2 FOR REVISION NUMBER 8 TOTAL 2F M

H REPORT DATE 7

2 4 FOR YEAR UP TO 18 - FACILITY NAME OTHER FACILITIES INVOLVED 8

8 TOTAL - DOCKET NUMBER 3 IN ADDITION TO 05000 9

1 OPERATING MODE 10 3

POWER LEVEL REQUIREMENTS OF 10 CFR II CHECK BOX THAT APPLIES UPTO F

NM LICENSEE CONTACT 12 qgpD ELEPH q CAUSE VARIES 2 FOR SYSTEM 13 4 FOR COMPONENT EACH COMPONENT FAILURE 4 FOR MAhdFACTURER EPIX VARIES SUPPLEMENTAL REPORT EXPECTED I4 CHECK BOX THAT APPLIES 8 TOTAL 2

M H

16 EXPECTED SUBMISSION DATE 4 FOR YEAR 121 NUREG-1022, Rev.1

NRC FORM 3SSA U.S. NUCLEAR RE10LATORY COMMLSION 1*c05)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME fil DOCKFT LER NUMBER (lil PAGE (3) yggq Sf0VENTIAL PEVIS.')N NUMSCR NUMBER 05000 OF TEXT tt! rrae space is reqwred, use e..dtonnel copres of NRC form 366A) (11) l l

l l

l I

l:

l

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NUREG-1022, Rev.1 122 NRC FORM 366A imm yyyy)

NAC FDAM 3644 U.S. NUCLEAR REGULATORY COMMIS$10N lMMYvtfY)

UCENSEE EVENT REPORT (LER)

FAILURE CONTINUATION mr F AClllTY NAME (1) l DOCKET l

LER NUMBER (6) t PAGE (3)

SEQUENTIAL REVislON vtAR NUMBE R NUMBER 05000 OF COM*LETF ONE LINE FOR E ACH COMPONENT FAILURE DEECRIBED IN THIS REPORT 113)

"^

^

CAUSE Sv5 FEM COMPONENT MANUFACTURER CAUSE Sv5 TEM COMPONENT MANUFACTURER 9 gg T EM t,:

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i-D M

k 7

l woRu asse IMu.vvvvi 123 NUREG-1022, Rev.1 i

a 1

r APPENDIX A

- HISTORICAL PERSPECTIVE ON EVENT REPORTING 1

NUREG-1022, Rev.1

Oriain of 10 CFR 50.72 and 50.73 In December 1980, the U.S. Nuclear Regulatory Commission (NRC) determined that requirements for reporting cperational experience data needed major revision and approved the development of an integrated cperational experience reporting (IOER) system. The lOER nystem was to combine, modify, and make mandatory the existing licensee event report (LER) system and the industry supported, voluntary nuclear plant reliability data system (NPRDS).

The NPRDS contains both engineering and failure data submitted by nuclear power plant licensees on specified plant components and systems. An advance notice of proposed rulemaking concerning the IOER system was published on January 15,1981 (46 FR 3541).

On June 8,1981, the institute of Nuclear Power Operations (INPO) siated it would assume responsibility for managing and funding the NPRDS and would audit member utilities to assess the adequacy of their participation in the NPRDS. The NRC believed the NPRDS would provide the necessary operating experience data and further development of the IOER syste m was discontinued.

On May 6,1982, the NRC published a notice of proposed rulemsking in the Federa/ Register (47 FR 19543) that would modify and codify the existing LER system. On Juiy 26,11183, after consideration of public comments, the NRC published in the Federa/ Register (48 FR 33850) a final rule under 10 CFR 50.73, which modified and codified the LER system and became cffective on January 1,1984. In the rule, the Commission clearly indicated that the NPRDS is a vital adjunct to 10 CFR 50.73 for component data.M The purpose of the rute was to standardize the reporting requirements for all nuclear power plant licensees, to eliminate reporting events of low individual significance, and to require more thorough documentation and analyses of reported events. Licensees are to submit such reports within 30 days of discovery. The revised system also permits licensees to use the LER procedures for various other reports required under specific sections of 10 CFR Part 20 and Part 50.

Also effective January 1,1984, the NRC amended its immediate notification requirements of significant events at operating nuclear power reactors (10 CFR 50.72) to clanfy reporting criteria cnd to require early reports only on those matters of value to the exercise of the Commission's responsibilities. The amended rule was published in the Federal Register (48 FR 39039) on August 29,1983, and corrections to the rule (48 FR 40882) were published on September 12, 1983. Among the changes made were the use of terminology, phrasing, and reporting thresholds similar to those of 10 CFR 50.73 whenever possible. Therefore, most events reported under 10 CFR 50.72 also will require an in-depth followup report under 10 CFR 50.73.

NRC Workshoos and Event Reoortina Guidelines in September 1983, the NRC staff published NUREG-1022," Licensee Event Reporting System," to provide supporting information and guidelines to persons responsible fer the m On January 1,1997 NPRDS was replaced by a new reporting system entitled Equipment Performance and Information Exchange (EPlX).

i A-1 NUREG-1022, Rev.1

preparation and review of LERs. NUREG-1022 includes (1) a brief description of how the NRC analyzes LERs, (2) a restatement of the guidance contained in the Statements of Consideration that accompanied the publication of the LER rule, (3) a set of examples of potentially reportable events with staff comments on the actual reportability of each event, (4) guidelines on how to prepare an LER and use the LER form, and (5) guidelines on submittal of LERs, Between October 25 and November 16,1983, the NRC held five regional workshops to discuss the new LER rule (10 CFR 50.73) and the revised emergency notification rule (10 CFR 50.72).

Supplement i to NUREG-1022 was publiched in February 1984 to provide a summary of answers to questions asked during the workshops.

Supplement 2 to NUREG-1022, issued in September 1985, contained evaluations of the quality and completeness of an industry-wide sample of 415 LERs. The study was performed for the NRC Office for Analysis and Evaluation of Operational Data (AEOD) by EG&G, Inc., at Idaho National Engineering Laboratory The report identifies deficiencies in LER content and recommends corrective actions.

NRC Reaulatory Imoact Study (Draft NUREG-1395)

In the fall of 1989, the NRC staff surveyed personnel from 13 nuclear power utilities to obtain their views on the potential effect that NRC regulatory activities were having on the safe operation of their nuclear plants. This survey w.' documented in NUREG-1395, " Industry Perceptions of the impact of the U.S. Nuclear Niutatory Commission on Nuclear Power Plant Activities," Draft, March 1990. Section 8, " Reporting Events," of NUREG-1395 included industry comments on reporting required by 10 CFR 50.72 and 50.73.

Specific industry concems included the need for reporting inadvertent actuations of engineered safety feature (ESF) equipment e

actuation of ESF equipment involving no safety significance e

plant shutdowns required by plant technical specifications even though the action l

e statements of the technical specifications were being met grass fires not affecting plant safety a

radiation exposures in excess of regulatory limits e

Amendment of 10 CFR 50.72 and 50.73 On September 10,1992 the NRC published a final rule in the Federal Register (57 FR 41373) to eliminate the requirement to report certain events which had been determined to be of little or l

no safety significance. These were events that resulted in invalid actuation of several specific

- engineered safety 'oatures.

l NUREG-1022, Rev.1 A-2 l

1

..____._ __ __. _ _ _. _._._.~ _... _ _ _ _. _... _

l i

l Other amendments'have been made from time to time in order to make these sections conform L

with changes in other sections.: For example, the requirements for reporting releases of f

radioactive material have been amended to conform with changes to 10 CFR Pa:t 20.

Revision of NUREG-1022 Partially in response to the industry's concerns regarding event reporting described in NUREG<

1395, the NRC sponsored four additional regional workshops on event reporting during j

September to November 1990.

L The NRC staff determined that additional clarification was needed to further improve the -

usefulness, quality, and threshold of reporting by the licensees under 10 CFR 50.72 and 50.73.

Therefore, a draft of Revision 1, to NUREG-1022, to encompass and supersede NUREG-1022 cnd Supplements 1 and 2, was published for comment in September 1991. In May 1992 and.

again in May 1993, public meetings were held to discuss the issues raised by public comments.

After addrest,ing these issues, a second draft was published for comment in February 1994.

l The intent of this Revision 1 is to clarify reporting requirements of 10 CFR 50.72 and 50.73 :

without changing those reporting requirements. Accordingly, most of the guidance is not new or different from generic reporting guidance previously published in the statements of considorations for the rules, NUREG-1022, its Supple'. ants 1 and 2, or generic correspondence such as generic letters and information notices. Tt,is final version of Revision; i

1 has been modified as appropriate te address public comments on the second draft that was published for comment in February 1994. Further, at the staff's initiative the instructions for preparation of LERs were_ augmented to address consistency of information provided in LERs which is used to understand events, as discussed in Sections 2.8 and 5.

4 I

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A-3 NUREG-1022, Rev.1 '

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APPENDIX B EMERGENCY NOTIFICATION SYSTEM PROCESS

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-NRC Prompt Response Personnel

- Headquarters _ Operations Officer -

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_ The U.S.' Nuclear Regulatory Commission (NRC) Operations Center is continuously staffed with j

sn NRC headquarters operations officer (HOO), who holds a degree in engineering and works for the Office for Analysis and Evaluation of Operational Data (AEOD). HOOs are trained to -

receive licensee notifications via the emergency notification system (ENS) made under Title 10 of the_ Code of Federal Regulations (10 CFR) Section 50.72. In addition, they are trained to 3

- receive materials, security or transportation events, as well as inquiries from the public or media. A second HOO is usually on duty during normal werking hours to help with the more frequent communications experienced during the work day.

3-Each HOO has previous nuclear experience and receives extensive classroom and simulator i

- training on both boiling-water and pressurized-water reactor systems at the NRC Technical :

iTraining Center.

. Although HOOs have a good general understanding of nuclear power plants, they do not have expert knowladge of each specific plant.' The HOOs ask questions and rely on the licensees to 7

explain plant specific details, terms, and the limiting conditions for operation of related technical specifications, to ensure they understand the significance of the event and are able to answer L

pertinent questions. The HOOs will attempt to obtain all of the details of the event that bear on Its safety significance, even if those details would not otherwise be reportable.

I The HOO determines, by procedure, how quickly the ENS emnt information needs to be disseminated to various NRC officials and other Federal agencies and prepares a written report L

of the oral ENS notification (ENS Event Notification Report) for electronic distribution to the NRC Office of Nuclear Reactor Regulation (NRR), NRC regional offices and the institute of Nuclear Power Operations, by 7:30 a.r. each weekday moming.

Emergency Officer If an emergency is declared or if it appears that the event may have significant plant-specific or generic interest to the NRC, the HOO notifies the emergency officer (EO). The EO is assigned on a weekly rotation from NRC staff members of the Senior Executive Service, and is on call 24

- hours per day, These are typically NRR division directors, assistant division directors, or branch chiefs, who are responsible for the NRC response to an event. The EO decides which

-: other NRC managers should be irJormed to participate in responding to the event. The EO also participates in deciding whether the NRC Operations Center and/or the applicable NRC regional incident response center will be partially or fully _ staffed to continuously monitor the

~ event.

- Regional Duty Officer

The HOO promptly informs the regional duty officer (RDO) of any ENS notification affecting the RDO's NRC region. The RDO, who is a senior NRC employee (typically a branch chief or B-1 NUREG-1022, Rev.1 t

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division director) in the applicable NRC region, is assigned a skly rotation and is on call 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day. The RDO informs the responsible NRC section ;hief and othe" NS9 staff, as needed. The NRC regional staff follow up on the plant specific aspects of ea. A Nnt through the responsible section chief, resident inspectors, and other NRC managers or tec';.nical experts, as needed.

Resident inspector If the safety significance of an event warrants or if the HOO can not obtain a clear understanding of an event, the RDO may request a resident inspector to immediately investigate, monitor, and report back to the NRC region and headquarters on the situation.

Licensees are encouraged to work with a resident inspector if they have a question regarding the reportability of an issue. If the resident inspector cannot provide guidance, he or she can direct the licensee through the region to headquarters for a more definitivo discussion. The resident inspector will not make the decision, but can advise what the regulations require. The resident inspector should be informed abtei an event whenever an ENS notification is made.

The NRC relies on the continuously staffed NRC Cperations Center, not the resident inspector, to naify the appropriate NRC staff of a reportable event.

NRC fhsponse to ENS Notifications NRC Response Options There is a wide range of typical NRC headquarters and region responses to an ENS notification, depending on the safety significance of the event, including:

The NRC Operations Center and the NRC regionalincident response center may be fully activated and a site team sent to the plant.

Specific NRC ctaff may monitor the progress of the event from the NRC Operations Center and/or regional incident response center and an NRC team may be sent to the plant.

A resident inspector may be requested to immediately investigate, monitor, and report back to the NRC region anc5r headquarters.

l Conference calls among NRC headquarters, region, and licensee management may be established.

The EO, RDO, and HOO may follow the progress of the event and request specific information from the licensee on a periodic basis until the plant is in a safe condition.

The RDO may receive the notification and contact the resioent inspector for additional l

information, l

NUREG 1022 Rev.1 B-2 1

Additional NRC Operating Event Review Each working day the NRR Events Assessment and Generic Communications Branch (PECB) and the AEOD Reactor Analysis Branch (RAB) obtcin copies of notifica%ns of events that were received in the NRC Operations Center since the beginning of the pretous working day.

Copies of the daiij report from each regional office also are obtained. These reports present the results of the regional offices' review of events occurring within the region since the previous working day, regardless of whether licensees have submitted notifications under 10 CFR 50.72.

Each working oay PECB and RAB personnel screen the notifications and regicnal daily reports to identify events that are potentially significant. A telephone conference follows at a preset time in the morning among representatives of PECB, RAB, the NRC Operations Center, and others. The conference callis made to discusc the significance of the events and identify specific events for further assessment. If an assessment is needed, engineers are assigned to determine what happened during the event, what caused the event, what the consequences might be, what corrective or preventive action is being taken, and whether that action is sufficient. If the event is still ongoing, then the engineer follows its development.

During assessment of the event, the assigned engineer determines whether the event is generic, significant, or both. The event is generic n iher nuclear power plants have the potential for occurrence of a similar event. Searches tf plant operationa! experience data bases may be performed by RAB personnel to identify similar occurrences and assess generic applicability. The event is significant if any of the following occurred:

potential or actual degradation occurred in safety-related equipment or structures, fuel e

integrity, the primary coolant pressure boundary, or containment release of radioactivity (in excess of 10 CFR Part 20 limits) occurred e

the plant was operated outside technical specification limits a

a scram with complications occurred e

e other conditions warranted attention by NRC If the event is classified as significant, senior NRC management are infonned at the next weekly events briefing meeting. Briefing information, including event summaries and diagrams, are placed in the Public Document Room (PDR). The event also is entered into the PECB significant event tracking system. Each quarter the significant events are compiled and published in the V '.C performance indicator report (" Performance Indicators for Operating Commercial Nuclear Power Reactors," issued oy AEOD and available in the NRC PDR).

Additional event followup actions performed by NRR, the appropriate NRC regional office, and AEOD personnel may include coneulting with the Executive Director for Operations in the selection of an incident investigatie n team (IIT), participating in the decision to dispatch an augmented inspection team (AIT) to the site and in the selection of the teGm members, or performing a human performance evaluation at the plant. The appropriate NRC regional office has the direct responsibility for routine followup and inspection related to reportable events.

B-3 NUREG-1022, Rev.1

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Depending on the number or types of event notWications by licensees NRR also may issue j

NRC generic letters, bulletins, and information notices.

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i APPENDlX C LICENSEE EVENT REPORT REVIEW PROGRAMS

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NUREG-1022, Rev.1

Title 10 of the Code of FederalRegulations (10 CFR) Section 50.73 specifies that licensee event reports (LERs) shallinclude a detailed narrative description of reportable operating experience, including safety significant and potentially safety significant events and conditions.

By describing in detail the events or conditions required to be reported, LERs provide information for detailed studies of events or conditions that might affect the health and safety of the public.

Variations in LER counts from plant to plant can result from numerous factors, only one of which is an actual difference in safety performance. Thus, the number of LERs submitted by a plant Fould not be used as a measure of the plant's safety performance.

In addition to prompt followup to ENS notifications described in Appendix 0, longer term followup of iicensee events is conducted using the LER information. The appropriate U.S.

Nuclear Regulatory Commission (NRC) regional office conducts plant specific followup, the Office of Nuclear Reactor Regulation (NRR) conducts plant specific and generic reviews, and the Office for Analysis and Evaluation of Operational Data (AEOD) and its contracted national laboratories, screen, classify, categorize, trend, assess, and store the data for each LER.

Those events and conditions, both plant specific and generic, that appear to be important to safety are further analyzed or evaluated. From this review process, the NRC determines further actions such as (1) a special study initiated to propose revisions to regulatory programs, (2) reporting as an abnormal occurrence to Congress, or (3) dissemination to the U. S. nuclear power industry through generic communications and to the international community through the Nuclear Energy Agency (NEA). The NEA is part of the Organization for Economic Cooperation and Development and gathers information from its member countries on the operating experience of commercial nuclear power plants worldwide.

Several fundamental objectives associated with the LER analysis process are to identify and quantify events and conditions that are precursors to potential severe o

core damage to discover emerging trends or patterns of potential safety significance e

to identify events that are important to safety and their associated safety concerns and o

root causes and to determine the adequa :y of corrective actions taken to address the safety concerns to assess the generic applicability of events e

A precursor to potential severe core damage is an event or condition that could have been serious if plant conditions, nersonnel action, or the extent of equipment failure or faulting had been slightly different than that which occurred.

An analysis of trends and patterns in operational experience identifies repetitive events and failures and searches past operating history for similar events and failures to determine if the frequency of such events or failures is significant enough to be a cause for concern. When C-1 NUREG-1022, Rev.1

appropriate, an NRC bulletin or information notice is issued or a generic study initiated to focus on the nature, cause consequences, and possible corrective actions of such a situation.

Trends and patterns analysis usually applies to events and conditions that individually are of low safety significance but that become a safety significant factor because of repetition or, more accurately, the frequency of occurrence.

AEOD studies of events that are important to safety are documented in the following reports:

Case study reports document substantive, in-depth analyses of safety issues and the bases for AEOD recommendations for regulatory or industry actions.

Special study reports document accelerated assessments of significant operating events and contain recommendations for remedial actions, if appropriate.

Engineering evaluation reports document assessments of significant operating events and contain suggestions for remedial actions,if appropriate.

Technical review reports document studies of issues that were determined to have little safety significance.

AEOD uses % i Sequence coding and search system (SCSS) data base for storage and retrieval od FR @: This system, developed in the early 1980's and maintained under contract at M drt # dge National Laboratory, Oak Ridge, Tennessee, contains an average of 150 items of infomiaJon in its data base for each LER submitted since 1980.

AEOD uses LER data from the SCSS data base to support NRC activities such as plant diagnostic evaluations, NRC senior management meetings, and performance indicators. The SCSS data base also is a primary source of information for AEOD studies. In addition, NRC's Office of Nuclear Regulation, Office of Nuclear Regulatory Research, and regional officer use the SCSS as a source of information on operating experience.

AEOD also maintains LER information in the trends and patterns data base at Idaho National Engineering and Environmental Laboratory (INEEL). This data case supports such specific AEOD studies as those covering performance indicator data for reactor trips, safety system actuations, and safety system failures. The INEL data base also is used to calculate forced outage rates and equipment-forced outages por 1000 critical hours, as well as to support the preparation of Commission site visit briefing packages, special studies, and the evaluations of selected plants.

The information from LERs is widely used within the nuclear industry, both nationally and internationally. For example, the industry's Institute of Nuclear Power Operation (INPO) uses LERs as a basis for providing operational safety experience feedback data to individual utilities through such documents as signiftant operating experienco reports, significant event reports, significant event notifications, and operations and maintenance reminders. U.S. vendors and nuclear steam system suppliers, as well as other countries and international organizations, use LER data as a source of operational experience data.

NUREG 1022, Rev.1 C-2

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APPENDIX D 1

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10 CFR 50.72 INCLUDING STATEMENT OF CONSIDERATIONS i

i Published in the FederalReglster On August 29,1983 (Vol. 48, No.168, pages 39039 39046)

NOTE:

This Feders/ Register notice does not provide a current version of 10 CFR 50.72, which has been amended several times since 1983. Its purpose here is to present the Statement of Considerations, which explains the basic reporting requirements of 10 CFR 50.72.

f NUREG-1022, Rev.1

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Federal Regio 6ee / Vol. 44. No.1es / hirnday. Austal 29, 1983 / Rules and Rml ti:ns 30039 Commission. Nashington. D.C. 30688; Telephone l301) 492-4973.

suertseasertany esseonesaveost I. Background On February 29,1900, the Commlulon omended its regul.nlions without prior nnlice and comment to require timely and accurate llornare reportmg of infortnation following significent events et operating nuclear power reactors (45 FR 13434).ne purpose of the rule was to proside the Commission with immediate reporting of twelve types of -

significant events where immediate Commissien action to protect the public health and eefety may be required or where the Commission needs accurate end timely information to respond to heightened public concern. Although the rule was made immediately effective, comments were solicited. Many commenters believed the rule wee in some respects either vague end ambiguous or overly broad.

After obtaining experience with notifications required by the rule the -

Comenission published in the Federal Register a police of proposed rulemaking on December 21.1981 (44 f1t 61094) and invited public comment. De proposalwas made to meet two objectives: change 10 CF1t 30.54 to implement Section 301 of the NRC's 1900 FiscalYear Authorisation Act and change 10 CFR 50.yt to snore clearly 10 CFR part 90 ePecify the significant evente requiring

'censees to immediately notify NRC.

Immedlete Notification Requiremente ne problems and lesues which this of Significant Events At Operatin9 rulemaking addresses and the solutions Nuclear powee Reactore that it provides can be summarized in Aeseecv: Nuclear Regulatory five broad ereas:

Commieeien.

1. Authorisation Actforn'80 Section 301 of the Nuclear Regulatory sucessany:%e Nuclur Regulatory Commiselon Authorization Act for Commission is amending its regulations Fiscal Year 1980 (Pub. L 96-295) which require timely and accurate provides:

In'ormation from licensees foliowinE (el section los of M Alemic Enway Act of significant events et commercial nuclear gest le amended by adding et the end thoveel power plante. EAperience with existing the following new. heest6ene: f.Eoch heense requiremente and public comments on a lueed for a utilisation facility under thee proposed revision of the rule indicate wetion er wenien 104b. ehell reevue se a that the existing regulation should be condei6en ow=d theiin eme of my oneidui amended to clarify reporting criteria and which could muh in en unplaned misese of to require early reporte only on those quenHues of Anien peduou in mesa of

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lue to the emereise of the estabhehed by the Commission,the beensee snettere of vae responalboude.Deshall immediately se notify the Commiseeen, amended regulation will clartly the liel vieleuen of the cond6i6en puerthed by this of reportable evente and provide the -

embeece6en may,la h Commession's f'h with more useful reporte descreteen constitute pseunde ler lisense the safety of opereung nuclar mecouen. in ace =denes wnh esena tor of powee to, this Aet. the Commieeien ohell amm M houwiwawHHuHe

day EPPECTfv6L Daft:lanuary 1.1994, loomed under this secteen er esce6en tesh..

Pen Isisamen meresusAmpel cosefACT:

which le in effect en die dele of onessment of Eric W. Weise. Offlee of laaraada= and this beestion te laelude the potenene Enforcement. U.S. Nuclear Regulatory -

ng.6,edunderthieembeemien.

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39040 rederal Reglatee / V:1. 48. No.108 / Monday. August 29. 1983 / Rules cod Regulati:ns Accordingly, this rulemaking indudes prepare detsited written reports for Comhtions o/Ucenses (f 503(/

an amendment to 10 CTR 50.54 that certain events (40 m 33850).

A kw comnienters said that the would add an appmpriate notification

( Coordnoss.on with Ucensee's

" Commission already has the ability to requirement as a condition in the Emetyency Plon enforce its regulations and does not operating license of each nudear utihrution facihty lice %I under section The current scheme for hcensers-need to incorporate the items as now 103 or 104b.of the Atomic Energy Act of emergency plans includes four proposed into' conditions of license."

1954, as amended. 42 USC. 2133. 2134b.

Emergency Cluses. When the licensee The Corr. mission has decided to These facilities generally are the declares one of the four Emergency prumulgate the proposed revision of commercial nuclear power facilities Classes,it must report this to the i 50.R "C:nditions of Licenses."in which produce electrtr.ity for public Commission as required by i 5012. The order tu satisfy the intent of Corgress as consumption. Researth and test reactors lowest of the four Emergency Classes.

esprened in Section 231 of the Nuclear are not s6;ect to the license condition Notincation of Unusual Event, has Regulator) Commission Authorization as they are licensed under section 104a.

resulted in unnecessary emergency Act for Fiscal Year 1080.This Act and or 104c. of the Act. Under the dedarations. Events that fall within the its rel.tionship to I $0 54 are discussed amendment to 10 CIR 5054. licensees Unusual Event class have been neither in detailin the Federal Register notice fallir.g under sections 103 or 104b. would emergencies in themselves nor for the proposed rule (40 FR 61094).

be required. u a condition of their precursors of more serious events that respective operstlnslicenses. to notify are emergencies.

Coordination With Other Rsporting the NRClmmediately of events specified Although changes to the definition of Requirtinents frino/ Ru/c f 5012/

in 10 CR 5012.

the Emergency Classes are not being Seven commenters said that the NRC should coordinate the requisements of 10

2. Unnecessory Report' re ort gs e a oul u timately Cm 5012 with other rules, with Several catego les of reports required climinete " Unusual Event" as an NUREG454. " Criteria for Preparation by 6 50J2 are not useful to the NRC.

Emergency Class requiring notification and Evaluation of Radiological Among these categories are reports of:

can be adopted consistent with this rule. Emergency Response Plans and worker injury, small radioactive A proposed rulemaking which would releases, and minor security problems, redefine the Emergency Classes in Preparedness in Support of Nuclear For example. reporta are presently i 50.47 is in preparation and may soon Plants." and with Regulatory Guide 1.16, required if a worker onsite experience be published for public comment.nis

" Reporting of Operating Information chest pains or another illn.as not related final rulemaking makes possible the

..." Many of these letters identined to radiation and is sent to a hospital for elimination of " Unusual Event" as an overlap, duplication, and inconsistency evaluation: or if the vent stack monitor emergency class withool further among NRC's reporting requirements.

moves upward a few percent yet amendment of I 50J2 by including in The Commiazion la making a radiation levela remstn 100.000 times the category of non. Emergencies the concerted effort to ensure consistent below technical specification limits: or if subcategory of "one hour reporta."

and coordinated reporting requirements.

the security computer malfunctions for a

5. Vogue or Ambiguous Reporting De requirements contained in the

)

revision of 10 CR 50J2 are being few minutes.

Criteria This rulemaking eliminates such coordinated with revision of l 50J3.

reporting requirements from 5 5072 and he reporting criteria in i 5012 have i 50.55(e). Appendix E of Part 50, in general clanf es and narrows the been revised in order to clarify their i 20.402, l 73J1. and Part 21.

scope of reporting. ilowever, revision of scope and Intent.De criteria were part 73 of the Commission's regulations revised for the proposed rule and in Citing JO CTR 50.72 os a Basis for is necessary to resolve all problems with response to public comment.Re Notificofion (fino/ Rule f 50.7tfo/((//

security reports.

" Analysis of Comments" portion of this A few commenters ob}ected to citing Federal Register notice describes in I 50J2 as a basis when making a 1 Terminology, Phrosing. and Reportin# more detail specific examples of telephone notification.The letters of Thresholds changes in wording intended to comment questioned the purpose. legal De various sections of 10 CR 50 eliminata vagueness or ambiguity.

effect. and burden on the licensee, have different phrssing, terminology.

II*And ** fCo""' I' The Commission does not believe that I

and thresholds in the reporting cnteria.

Even when no different meaning is Twenty leners of comment were it is an unnecessary burden for a intended a change in wording can cause received in response to the Federal licensee to know and identify the basis confusion.

Register notice published on December for a telephone notification required by 21.1981 (46 m 61894).' Of the twenty i 50J2.There have been many 1

His rulemaking has been carefully letters of comment received, the vast occasions when a licensee could not tell written to use terminology. phrasing, and reporting thresholds that are either majority its of 20) wers from utilities the NRC whether the ielephone identical to or similar to those in i 50J3. owning # opwoung nuclear power notsBcation was being made in whenever possible. Other conforming plants.%is fedecal Re ;ister notice accordance with Technical amendments to Parts 20,21. 73, and in described the proposed revision of to Specifications.10 CFR 50J2. eome other CR 5072. "Notificath a of Significant requirement. or was just a courtery call.

i 5053 and Appendia E of Part 50 are Evente. and to Cm 60.54 " Conditions Unles thelicensee can identify the under development.

of1Jcenses. A discussion of the more nature of the report,it la difficult for the As a parallelactivity to the

'I " C8"I C0"*"'"I' IONO*8:

NRC to know what significance the I

preparation of I 50J2. on july 26,1983.

the Commission has published a licensee attaches to the report, and il 1Jcensee Event Report (IIRJ Rule

' c.p..I ama--- = mg.w s" becomes more difficult for the NRC to il 5033) which requires licensees for

@ONT$'

'w7c respond quickly and properly to the M

operating nucleari ewer planle to W w se6 o n aussa event.

l'ederal Register / Vol. 48. No.168 / hinnd:y. August 20.19u3 / Itutes and Regulations 39041

/mmediate Shutdown (Ano/ Rule airborne concenttritions decrease or occurritig at operstmg nuclear power j 50 n/b)(1)l///

until respiratory protection deuces are plants. A deadlme shorter than one hour Ses eral commenters objected to the utilized.They noted that these es ems was not adopted because the are fairly common and should not be Comtmation does not want to interfere use of the term."immerliste shutdown."

saying that TechrncarSpecifications do apnnaWe unless the required n ith the operator's abihty to deal with nacuatmn eHects the entire fanhty or a

.in accident or tr.irment in the first few not use such a term.

The term is used in some but not all malw pan of H.

cntical rmnutes.

ne Commission agrees. The woidmR Thmfue. based on these terunents Technical Specif cations. Consequently, of diis ontnion has been changed to and 6ts empenence the NRC has the Cornmission har tes tsed the

'N' *"I Aose cunts which establahed a "four. hour report.,'.is un F

reportmg criterion in questinn. The final sign can4. haniper de aW M sh upsted rule requires a repori u on the trutistion of any nuclear power p unt shutdown

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,'g"g,g[gp,",'h Reactor Scroma It'irn/ Rule E

required by Technical Spera0 cations.

One commenter was concerned that fM72/bl/?)(iiff I'/unt Operating cnd. Emergency events occurring on land ow ned by the Several comrnenten said that reactor l'rocedures (fino/ Rule f M 72/b)(if/////

utility adjacent to its plant might be scrams, particularly those scrams below Several comrnenters said that the up na W:is not the intent of this power operation, should not require np rting requirement.The NRC is notification of the NRC within one hour.

r: porting criteria should not make c ncerned with the safely of plant and in response to these comments, the reference to plant operating and pusenel n the uuhty a site and not Commission had changed the reporting ernergency procedures because:

"acuviun nland deadline to four houn. llowever, the

c. It would take operators too long to

18"'

' ' Pj8"t-Commission does not regard teactor dIcide whelher a plant condition was cov; red by the procedures.

Explicit Threats (rinalRu/c serams ae "non-events." as stated in b The procedures cover events that f M72(b)/J)(ri))

some letters of comment. information related to reacter scrams has been are not of concern to the NRC and A few commenters said that the intent usefulin iderwying safety related

c. ne procedures vary from plant to of the term.

explicitly threstens." was pl nt.

unclear. nose commenting wondered pmblems. %e Commission agrees that While the plant operating penonnel what level of threat was involved.ne four h urs is an appropnete deadline for sh:uld be familiar with plant term. " explicitly threatens. " has been this reporting requiremeat because these procedures, it is true that procedures deleted from the final rule. Instead the nents an ut u imponent k very from plant to plant and cover final rule refers to "any event that poses immediate safety as are some other ev:nts otner than those which an actual threat to the safety of the "ents.

compromise plant safety. llowever, the nuclear power plant" ll 50.72(b)(1)(vi))

Rodlooctive Relcose Threshold (rinal wording of the reportmg criteria has and gives examples s'o that it is clear the Rule f M72(b)(f)(iv))

been mod Ded (l I472(b)(1)(ii)in the Ccmmission is interested in real or Several commenters sold that the fin:t rule) to narrow the reportable actual three.a as opposed to threats threshold of 25% of allowable limits for events to those that significantly without credibility, radioactive releases was too low for compromise plant safety, Notwithstanding the fact that the Notification Timing (fino/ Rule one hour reportmg.

procedures very from plant to plant. the fM70lbll21)

Based upon these comments and its Commission has found that this enterion ne commenters generally had two experience, the Commisalon has r:sults in notincations indicative of points to make regarding the timing of changel the threshold of reporting to sIrious events. %e narrower. more reports to the NRC. I'irst, the comments those releases exceeding two times Part specinc wording will make it possible supported notincation of the NRC after 20 concentrations when averaged over a f:r plant operating personnel to identify appropriate State or local agencies'have period of one hour. nis will eliminate reportable events under their specthe been notified. Second two commenters reports of releases that represent operating procedures.

requested a new four to six. hour report negligible risk to the public.

C*""""'*""*""

Building Erocuation(FanoiRule

' * " 8 *'I I*' * ' * ' * ",* ' " "' * " U "8

level radioactive releases below two report with one hour J 2 71(b)(J/(iill)

Allow ng more time for reporting times part 20 concentrations do not, in Ten commenters said that the some non-Emergency events would themselves, warrant immediate proposed i 50.72(b)(6)(lii) regardins lessen the impact of reporting on the radiological response.

any accidental, unplanned or individuals responsible for maintaining his paragraph requires the reportmg uncontrolled release resulting in the plant in a safe condition.1.imiting of those events that cause en unplanned ev:cuation of a building" was unclear the extension of the deadline to four or uncontrolled release of a significant and counterproductive in that it could hours ensures that the report is made amount of radioactive material to offstle cause reluctance to evacuate a building.

when the ir.Srmation is fresh in the areas. Unplanned releases should occur huny of these commenters stated that minds of those involved and that it is infrequently: however, when they occur, the reporting of in-plant releases of more likely to be made by those at leset moderate defects have occurred radioactivity that require evacuation of involved rather than by others on a later in the safety design or operational individual rooms was inconsistent with shift.

control established to avoid their the general thrust of the rule to require Other, more significant non-occurrence and, therefore these events reporting of algnificant events.%ey Emergency events and all declarations should be reported.

noted that minor spilla, small gaseous of an Emergency must continue to be PersonnelRodioactive Contamination waste releases, as the disturbance of reported within one hour.ne one. hour contaminated particulate matter (e.g deadline is necessary if the Commission (fino/Rulef 272(b)(2)(v))

dut) may all require the temporary is to fulfillits responalbillues during and Several commenters objected to the evacuation of Individual rooma until the following the most serious events use of vague terma such as " extensive

39042 Tcder:l Reglster / Vol. 48. No.108 / hionday. August 29. 1983 / Rules and Regulslions onsite contamination" and *reedily from a license condition or technical the containment). Examples of this type removed"in one of the reporting criteria specifer.alion, of situation include; of the proposed rule.

Torogmph M72/bf/1)///).

(a) fuel cladding failures in the flased on this comment. new cnleria encompassing events previously reactor, or in the storage pool, that have been prepared that use more classified as Unusual Events and some enceeJ espected values or that are specific terme. For enemple, one new events captured by p*oposed unique or widespread, or that are cnterion requires reporting of "Any

($07:1u)(1) w as added to provide for caused by unespected factors, and event requinns the transport of a consistent, coordinated reporting would invol e a tslease of significant radioactively contaminated person to en requirements between this rule and to quantities of fusion products.

offsite medical facilily for treatment."

CFR !.0.73 which has a similar provision.

(b) Cracks and breaks in the piping or Exptrience with telephone notifications Public comment suggested that there reactor vessallsteel or prestressed made to the NRC Operations Centet should be similarity of terminology, concrete) or major curuponents in the suggests that this new criterion will be phrasing, and reporting threshnids primary coolant cirevil that have safety easily understood.

betricen i 27 and I !,0.73. De intent relevance (steam generators, reactor of this peragraph is to capture those coolant pumps, valves, etel til. Paragraph.by Paragtsph r.xplanation esents where the plant, including its (c) Significant welding or materist of the Rula principal safety barriers, was seriously defects in the primary coolant system.

Porograph M71/of reflects some degraded or in an unanalyzed condition.

(d) Serious ternperature or pressure consolidation oflanguage that was For example, small volds in systems transients.

repeated in various subparagraphs of designed to remove heat from the

[e) kas of relief and/or safety valve the proposed rule !n general, the intent reactor core which have been previously functions during operation.

and scope of tble paragraph do not shown through analysis not to be safety (f) loss of containment function or r flect any change from the proposed significant need not be reported.

Integrily including

rule, l{owever, the accumulation of volds that (1) Containment leakage rates Several titles were added to this and could inhibit the ability to adequately exceeding the authonted limits, subsequent sections. For example, remove heat from the reactor core.

(li) Loss of containment isolation paragraph 272(b)is titled "Non.

particularly under natural circulation g.alve function during tests or operation.

conditions, would constitute an Emergency Events" and it has two (111) Loss of main steam isolation subparagrapha:(b)(1). titled *One-flour unanalysed condition and would be valve function during test or operation.

Reports" and (b)(2). ' Tour.ilour reportable,in addiuon. volding in instrument lines that results in an Reports." ne events which have a one, (iv) Loss of containment cooling erroneous indicauon caua the hour deadline are those having the capability potential to escalate to an Emergency operator to rnisunderstand e true Class.De four. hour deadline is condition of the lent is also an p,,,s,,p3 g7773j7;j7jgj,

""8"'I red con ition and should be encompassing a portion of proposed Y

explained in the analysis of paragraph M7 as rmorded to corruped d

A 73(a I (il). a ng the to itemente froP M7t(b)flg/f/A) requires

,,ngi nt reporting of "the initiation of any and experience to determine whether an of to CPR 272 and m73 similarin nuclear plant shutdown required b{ the unanalyzed condition existed. It is not language increases the clarity of these TechnicalSpecifications. Althoug intended that this paragra h apply to rules and mitumises confusion.

intent and scope have not changed, the minor variations inindivi ual ne paragraph has also been change in wording between the parameters, or to problems concerning reworded to make it clear that it applies proposed and final rule is intended to clattfy that prompt nottfication is single pieces of equipment. For example, only to acts of nature (e g tornsdoes) at any time, one or more safety related and external hazards k g., railroad tank required once a shutdown is initiated.

components may be out of service due car explosion). References to acts of in response to public comment. the to testing. maintenance, or a fault that sabotage have been removed. since tirm immediate shutdown" that was has not yet been repaired. Any trivial these are cos cred by i 72.71 In addition, used in the proposed rule is not used in single failure or minor error in threats to personnel from intemal the final rule.The tenn was vague and performing surveillance teste could hazards (e g radioactivity releases) that unfamiliar to those licensees who did produce a situation in which two or her.iper personnel in the performance of not have Technical Specifications using more often unrelated, safety grade necessary duties are now covered by I '""'

components are out.of service.

paragraph M72(b)(1)(vi).This paragraph his reporting requirement is intended Technically, this is an unanalyzed covers those events involving an actual ta r.Jpture those events for which condition. However, these events should threat to the plant from an external Technical $pecifications require the be reported only if they involve condition or natural phenomenon, and initiation of reactor shutdown, his will functionally related components or if where the threat or demage challenges provide the NRC with early warning of they algnificantly compromise plant the ability of the plant to continue to safety significant conditione serious safety. When applying engineering operate in a safe manner (including the enough to warrant shutdown of the judgement. and there is a doubt onlerly shutdown and maintenante of l

P ant.

regarding whether to report or not, the shutdown conditions).The licensee A8fDSMPh E72(b)(Igi)(B) was added Commission's policy is that licensees should decide if a phenomenon or t) be conelatent with existing should make the report.

condition actually threatens the plant, requirsments in i m.54(x) and the Finally this paraproph alsoincludes For example, a minor brush fire in a calating i 40.72(c) as publisbod in the material (e.g metauurgical or chemical) remote area of the site that la quickly Federal Register on April 1.1983 (48 FR problems that cause abnormal controlled by fire fighting personnel and.

13906) which require the licensee to degradation of the principalsafety as a result, did not present a Areal to noti the NRC Operations Center by barriers (i.e., the fuel cladding, reactor the plant should not be reported.

te when me lio.nsee departs coolant system pressure boundary, or However a major forest fire. large-ecale

~.

rederal Resialer / Vcl. 4a. No. sta / Monday. August 29. 1983 / Heles nml Regul:ti:ns 39013 flood, or maior earthquake that presents

5. platit monitors necessary for is pi.pihte. lu cause these personnel will a tint threat to the plant should be' ar.cident assessment.

hase a better knowledge of the reported. As another easmple, an parutntph M72(b)(J)fri).

circun stances associated with the sent.

Industnal or transportation accident entompcning some portions of the Reports rnatic within four hours of the w hich occurs ricar the site, creating a proputed il 50 72(b)(2) and (6). has esent shouhl rnake this possible while plant s lety concem should be been resised to add the phrase, not imposing the more rigid one hour reported.

"includeng hres, toxic gas releases. or requircuwnts.

Fotosmph M72lb)(I)(iv).

tortonnotac releases." nis addstson The n.portwg requorement in encompassmg events previously omers the "es secation" portion of pun:p.:ph /a 7.*/b//2)(i)is similar to a tiessified as L?nusual Es ents. requires paragraph 50 72(b)!O)llill of the proposed rerpmement m l $n r3 Moreover. rurpt the reporting of those etents that result rule. This change in wordmg for the final for referring to a shutdown reactor, thin in either automatic or manual actuntmn tule u.as made in response to pubhc reportmg requirement is also similar to c( the ECCS or would have resulted in commente discussed above.

the "One l hiur Report" in at.tisstion of the ECCS if some While palegraph 5012(b)(1)(iii) of the g en 72(li)(1)(ii),llowever this parngraph component had not failed or en operatur final rule peimanly captures acts of apphra to a rem. tor in shutdown action had not been teken.

nulure, paragraph 50.72(b)(1)(vil rornhtion. Esents within this f or example.6f a valid ECCS signal captures other events, particularly acts requirement have less urrency and can wart generaled by plcnt conditioris. and by personnel. The Commission believes be reported within four hours as a "Non.

thz operator were to put all ECCS this arrangement of the reporting criteria Emetyency."

pumps in pull tu lock. though no ECCS in the fmal rule lends itself to rnore romproph M72(b)(21///f tproposed discharge occuned, the event would be precise interpretion and is consistent

$012(b)pl)is made a "Non. Emergency" reportable.

with those pubic comments that in response Io public comment. because A Sahd signal" refers to the actual requested closer coordination between the Commianlon agrees that the covered pt:nt conditions or parameters the reporting requirements in this rule events generally have slightly less sciisfying the requirements for ECCS and other portions of the Commission's urgency and sniety significance than initistion. Excluded from this reporting regulations.

those events included in the "One.Ilour requirement would be those instances This provision requires reporting of g,po,g, where instrument drif t. spurious signals.

events, particularly those caused by acts hum:n enor, or other invalid signals of personnel which endanger the safety ne intent and scope of this reporting caus:d actuation of the ECCS. Ilowever, of the plant or interfere with personnel requirement have not changed frorn the sudi events may be reportable under in performance of duties necessary for pm rule.%Is pengmph h other sections of the Commission's safe plant operations.

intended to capture events during which reg lations based upon other detalls;in De licensee must esercise some an PSF actuates, either manually or p:rticular, paragraph $0J2(b)(2)(ll) judgment in reporting under this section.

automatically, or falls to actuate. ESFs requires a report within four hours if an For example, a small fire on site that did are provided to mitigate the Engmeered Safety Feature (ESP)is not endanger any plant equipment and consequences of the event:therefore {1) theY should work roperly when called E

actuited.

that did not and could not reasonably be Empenence with no.ificatians rinde espected to endanger the plant. is not uPon und l2) they should not be pursuant to I 60.72 has shown that reportable, challenged unnecessarily.De events involving ECCS dischstge to the parogmph 50.72(bf/ff of the proposed Commission is interested both in events rule was split into j 60.72(bl/f//li) and where un ESF was needed to rnitigate vessel are generall more serious that.

ESF actuations witbut discharge to thef 50.72/L)(2/(i)in the final nde in order the cm. sequences of the event (whether vcesil. !)ased on this experience. the to permit some type of reports to be or not the equipment performed Commission has made this reporting made within four hours instead of one pmperly) and events where an ESF critenon a "One.Ilour Report."

hour because these reports have less operated unnecessarily.

Ibrogmph 50.12(b//1,(v).

safety significance.in terms of their

" Actuation"of multichannel ESF encompassing events previously combined effect, the overall intent and Actuation Sptcms is defined as clsssified as Unusual Events covers ocupe of these pengraphs have not actuntion of enough channels to those events that would impair a changed from those in the proposed rule. complete the minimum actuation logic.

hcensee's ability to deal with an Since :he types of events inteeded to be nerefore, single channel actuations, errident or emergency. Notifying the captured by shis reporting requirement whether caused by failures or otherwine.

NRC of these events may permit the are similar w i 50J2(b)(1l[li), except are not typortuble if they do not NRC to take some compimsating that the reacwr is shut down, the reader complete the minimum actuation logic, micsures and to more completely assess should refer to the explanation of Operation of an ESF as part of a th) consequences of such a loss should I 50J2(b)(1)(ii) for more details on pla..ned test ur operational it occus.dunng an accident or intent.

evolution need not be reported, amergency, Pomsmph 50.72(b)(2) Although the llowever. if during the test or Examples of events that this criterion reporting criteria contained in the evolution the FSF actuales in a way that is intended to cover are those in which subparagraphs of 5 50J2(b)(2) were in is not part of the planned procedure.

cny cf the following are not available:

the proposed rule,in response to public that actuation should be reported. For

1. Safety parameter display system comment the Commission established example. if the normal reactor shutdown (SPDS).

this "Non. Emergency" category for procedure requires that the control rods

2. Emergency Response Facilities those events with slightly less urgency be inserted by a manuai reactor trip, the (ERI"s).

and less safety significance that may be reactor trip need not be reported.

3. Emergency communications reported within four hours instead of flowever,if ennditions develop during I:cilities and equipesant including the one hour.

the shutdown that require an automatic Emergency Notification system (ENS).

De Commission wants to obtsin such reactor trip, such a reactor trip should

4. Public prompt Notification System reports from personnel who were on be reported. ne fact that the safety meluding sirens, shift at the time of the event, when this

_-__J a.__

4

._..+

AJ AaM 6 J _

A

_a__-.*-m44 9044 Tederal Register / Wl. 48. No.168 / M:nday. August 29. 1983 / Rul:s end Regulations nelysis assumes that an I;ST will service to perform maintenance and the criterion. Tor example, the Commission cluste automatically during an event Technical Specifications permit the is increasingly concerned about the oes not eliminals the need to report resulting configuration, and the system effect of a loss or degradation of what ist actuation. Actuations that need not or cornponent is returned to service had been assumed to be nonenential e reported are those initiated for within the time limit specified in the inputs to safety systems. Therefore, this tasons other then to mingate the Technical Spec 6fications, the action paroErsph also includes those cases onsequences of an event (e 3.at the need not be reported under this where a sersice le p-. heating.

iscretion of the licensee ee part of a paragraph Ifowever,if, while the s entilation, and cooling) or input le p.,

lanned procedure).

component is out of service, the licer:See compressed air) w hit.h is necessary for identifics a condition that could have reliable or long term operallon of a

/'oropo/>h M 12/bfll////// (proposed prevented the system from performing safety 6) stem is lost or degraded. Such 011(b)(4)) has been revised and its intended function le g., the licensee loss or degradation is reportable.if the imphfied.

Onds a set of relays that is wired proper fullaliment of the safely function 1r e words *any Instance of personal incorrectly), that condition must be le not of can not be sputed, failures tror, equiprnent failure. or discovery of reported.

that affect inputs or services to systems IIsign or proceduralinedequacies" that it should be noted that there are a that have no safety function need not be appeared in the proposed rule have been limited number of single. train systems reported.

cndition/y the words " event or that perform safety functions (e g., the finally the Commission recognites cplaced b nie elmplification in liigh Pressure Coolant injection System that the licensee has Io decide when anguage is intended to clarify what was in llWRs). For such systems. loss of the personnel actions could heve prevented a confusing phrase to many of Noe single train would prevent the fulfillrnent of a safety function.Ter cho commented on the proposed rule.

fulfillment nf the safety function of that casmple, when en Individual imptoperly 8Liso in response to puhuc comment, this system and, therefore, must be reported operates or maintains a component, that cporting requirement is a "Non.

even though the plant Technical person might conceivably have made Emergency" to be reported within four Specifications may allow such a the same error for all of the functionally tours instead of within one hour.

condition to exist for a specified length redundant cornponents (e g if an

%Is paragraph le bened on the of time. Also.lf a potentially serious individual incorrectly calibrates one soeumption that safety related systems human error is made that could have bistable ampliner in the Reactor and structures are intended to mitigate prevented fulfillment of a safety Protection System, that person could the consequences of an accident. While function, but recovery factors resulted in conceivably incorrectly calibrate all paragraph M72(b)(2)(ll) applies to the error being corrected, the error is bistable amplifiers). l{owever, for en actual demands for actueuou of an 1:SF.

still reportable.

event to be reportable it is necestery paragraph 50.72(b)(2)(lli) covers an ne Commission recognises that the that the acdons actually affect or event where a safety system could have application of this and other paragraphe involve components in more than one failed to perfonn its intended function m this section involves a technical train or channel of a safety system, and because of one or more personnel errors, judgment b licensees. In this case, a the result of th sctions must be including procedure viofauons; technical j gment must be made undersirable fum the pctspective of Ipment failures: or deelsn. analysle, whether a adure or operator action that Erotecting the health and safety of the f; r1 cation, construct'on, or irocedutal disabled one train of a safety system' I

d;ficiencies. The event abou d be could have, bst did noi. affect a public.The components can ;s r: ported regardless of the altuation or redundant train. lf so, this would suncti nelly redundant (e s., two p mps I" dIII'"' II 'I " ' I""i "* I redundant (e g,"the opere, tor conectly c:ndition that cauwd the structure or constitute an eveat that "could have system to be unevellable.

revented" th6 fulfillment of a safety nl reporting requirement is similar function, and, accordingly, must be stops a Pump in Trait A, and,instes i

of shutting the pump discharge valve in is one contained in i 60.73, thus tied. -

)

renecting public comment idenufying teff a component falls by an apparentlyTrain "A." he mistakenly shuts,the the need for closer coordination of random medanism. it may or may not pump discharge valve in Train D,t.

reporting requirements between 160.72 be reportable if the funct;onally PoroFrophs Sa72(b#f#n)(proposed and i 50.73.

redundant component could fall by the 50.72(b)(6)) has been changed to clarify His paragraph includes those safety same mechanions. To be reportable, it is the requirement to report releases of systems designed to miugate the necessary that the failure constitute a radioactive material. ne paragraph is consequences of an accident;

g, condition whee, there is reasonable similar to i 20.403 but places a lower containment isolation emeryncy doubt that t$e functionally redundant threshold for reporting events at 0.tration). llence, minor operational train or channel would remain commercial power resciors. ne lower cvents such as valve packing inks, operational until it completed its safety threshold 8e based on the significance of which could be coneldseed a lack of function er is repaired. For example, if a the breakdown of the licensee's program control of radioacuve insterial, should pump falls because of improper necessary to have a relesw of thle alte, not be reported under this paragraph.

lubrication, there is a reasonable rather than on the significance cf the System leaks or other similar events expectation that the functionally impact of the actual release.De may, however, be reportable under other redundant pump, which was also existing licensee radioactive material paragraphs.

Improperly lubricated. would have also eInvent release monitoring programs his paragraph dow not include those failed before it completed its safety and their associated assessment cases where a systens er component is function, then the failure is reportable capabilities are sufficient to satisfy the removed from servios se part of a and the potential failure of the intent of 50.72(b)(2)(lv).

planned evolution in accordance with functionall Based upon public comment and a an oppioved procedars, and in reported. y redundant pump mutt be reevaluation by the Commission staff, cecordance with the plant's Technical Interection between systems, the reporting threshold has been Specifications. For example. If the particularly a safety system and a non.

changed from "255"in the proposed rule licenace removes part of a system from safety system,le nieo included in this to "2 times"la the final rule and has

f*cderal Register / Vol. 48. f40 It.8 / Monday. August 29.1(4tl3 / Rules and Kes:ulations 39045 been reclassified as a "Non Emerseccy" respond berause of media or public tht ul Subints in 10 CFR Part 50 lo be reported withm four hours insiced attention.

Antiituit. Cl.assific'd information. Fire of wsihin 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Nmgmph Mr#r/ (proposed 50 72lc))

Also this reporting requirement has has rernuined essentially unchanged pruention. Inu rptsrution by aclerente.

been changrd to make a more uruform from the proposed rule, esupt for inktguvernmental reluHons. Nuclear requirement by referring to specific addition of the title " followup pmr plants and reactors, peneegty, release ca.irna instead of refernns only Notification" and some renumbering R..diatism proterlion. Reactor siting to Tec.bnic,d Spcofications that may nis par.sgraph is intended to pioside uden( Heporung and rrronbelug i nty sorm what emong faciliues-the NRC with timdy notification when

'04"""""'"

nis etporting requirement is intended en egent becomes more serious or P"'*"*'nt to the Atomic Energy As1 of to capture those esents that anay lead to additionalinformation or new on.alyses 1954 as ametuted. the Energy an acudent situation where significant clarify an esent.

RCO'Nd"'Edi"'" ALI CI IV74 " "*""d"d' amounts of radioactive material r.ould be released from the facility. Unplanned This paragraph also pern.its lhe NRC and ses. tion h52 and 553 of Tille 6 of the to rnmentain a continuous United Sintes Code, the following ieleases should occur infrequendy' communications channel because of the amendments tu Title 10. Ch.ipler 1. Code howeser,if they occur at the levels specified. at least moderate defects have need for e.ontinuing follow.up of Federal Regulations. Part 50 are information or because of published as n' document subject to 17stablibed to avoid telecommunicaHons pmWmt codMr.nunn.

e at onal n Iheir occurrence and, therefore, such IV. Regulatory Anelysis events should be tegried~

PART S0--DOMESTIC UCENSING OF fiormal operating limits for

'k(

PRODUCTION AND UTIUZATION g

,nal I n lon.

rcdioactive effluent releases are based rActuitES he analysis enemines the costs and est b$ist es ma benefits of the Rule as considered by the

1. %c authuniy citation for l' art 60 m m ann a a rage concentrahon in unrestricted areas.~ %is Cornrnission. A copy of the regulatory continues to tend as follows:

I reporting requirement addresses

' g,*,",* g* *,' "R fv ic

^8tha'i'Y: 6"* 103.104, tot.1al int in concentrations averaged over s one hour period and represents less thatt Document Room. 171711 Street. NW.,

teus sist. em s37. 94a. ess. es4. ess. um es 0.1% of the annualquantatics of Wash ngton. D.C. Single copies of the amended. sat 234. 63 Stol 1244. es emended tsdioactive materials permitted 1o be ana ysis may bo obtsined from Eric W.

142 US C 2133,2134.1201.2232,223L 22N.

rsteesed by 10 CFR Part 20.

Weiss. Off' ace of InspecHon and 2239. 22A2h seca. TH 30L 308. SS Stat.124L Porogroph MT2(bf/2)(cf (proposed Enforcement. U.S. Nuclear Regulatory 1244.1246. ee amended 142 US C 241. 24L g

g rule 50 72(b)(7)l has three changes. %e Comrnissbn. WeWngton. E. N5.

tion af elso issued under pub. L 95-Drst eliminates the phrase

occurring Telephone l301) 492-4973.

sot. eec. to. v2 5tet. asst l42 0S C 645tl.

onsite" because it is implied by Ihe V. Paperwork Reduction Act Ststement scrisons so sn. fc et end 60 m2 eleo issued scope of the rule.he second replecte under pub.1.97-415. se Stat. 3073142 t!S C

" injury involving radiation" with De information collection M rs Ao imd eder a

" radioactively contaminated person.a requirements contained in this final ruse UE IW Wes his change was made because of the have been approved by the Office of s

so mbsn at etsu issued under ser 164.rie Stat.

difficully in defining (~

due to Management and Budget pursuant to the

,,gg, g3 g g g,,,

ridiation. and more importently.

Paperwork Reduction Act. Pub. L 96-511 50 unkso 102 elmo issued under sec. tm he because 10 CFR Part to captures events (clearance number 3150-00111 siet 955 (42 US C 22361 involving rediation exposure.

VI. Regulatory Fletibility Certification for the eurposes of ecc.122. e4 sist. osa. ee he third change in response to public comment, was to make this

,in accordance with the Regulat,ory amendi@2 Us C 2273). II mto tal. Ibl.

and M. w n u M n m R and M m el reporting requirement a four. hour Fiexibility Act of 1980. 6 U.S.C. 005(bl.

are inwed under occ.1oth. es sist. 94a. es notincation instead of one.hout the Commission hereby certifies that amended I42 U S C 22mtbil. Il so tu tbl and notification. Dis change was made this regulation will not have a kl and *c 54 ore issued under acc.1816. to because these events have slightly less signliicant economic impact on a sist u49. un amended (42 US C 22m(611. and sticty significance than those required substantial number of smallentities.

Il m ssM. no 59(bl. 270. 60.71. 6072, and to be reported within one hour.

Dis final rule affects electric utilities So fa eti issued una ecc.161o. r4 Stet. 9%

Puragmph 30.72(b)(2)(rif (not in that are dominant in their respective en omended (42 US C 22011n11 proposed rule l bes6 des covering some service areas and that ohn and operate events such as release of radioactively nuclear utilisation facilities licensed

2. A new paragnph (t)is udded to contaminated tools or equipment to the under sections 103 and 104b. of the i 5054 to rend as follows-public that may warrent NRC attendon.

Atomic Energy Act of 1954, as amended.

cleo covers : hose events that would not De amendments clarify and modify I60.54 Conditione of licenses.

otherwise warrant NRC attention es cept presently existing notification for the interest'of the news media, other requirements. Accordingly, there is no government agencies, or the public. In new, significant economic impact on (t) Euch licensee with a utilizaHon IIrms of its ellect an licensees this is these licensees, nor do the affected facility licensed pursuant to sections 103 not a new reportlag requirement licensees fall within the scope of the or104b.of the Act shellimmediately because the threabold for reporting definition of "sniall entitles" set forth in riotify the NRC Operations Center of the injuries and radioactive release was the Regulatory Flexibility Act or within occurrence of any event specified in much lower under the proposed rule.

the Small Business Site Standards set i 50.72 of this part.

His criterion will capture those events forth in regulations issued by the Small previously reported under other criteria Business Administration at 11CFR Part

3. Section 50.72 is revised to read as when such events require the NRC to 121.

follows:

39M6 Feder:I Register / Vol. 48. No.16s / Monday August 29, 1983 / Rulza and R:guintions i to 72 Immestate nouncat6*a (C)In a condition not covered by the when averaged oser a time period of eeeuhements for operenng nuctor po**r plant's operating and emergency one hour.

"*d*'*-

procedures.

(D) Any liquid effluent telease that (a) Centro / Requirements.' (t) Each (iii) Any natural phenomenon or other exceeds 2 times the limiting combined nuclear power reactor under 6 60 21(b) esternal condition that poses an actual Maximum permispble Concentration or i 50 22 of this part shall notify the threat to the safely of the nuclear (MpC)(ste Note 1 of Appendit D to Part NRC Operations Center via the power plant or significantly hampers to of this chapter) at the po.it of entry Emergency Notification System of:

site persor.nel in the performance of 8 *

(i)The declaration of any of the duties necenary for the safe operation

[" I

'j' ayionudides Emergency Classes speci..ed in the of the plant.

licensee's approved Emergency Plardor (iv) Any event that results or should except tritium and dissoIved noble (ii)Of those non EmerFency esents have resulted in Emergency Core E'8CS when averaged over a time period specified in paraftsph (b) of the section.

Cooling System (ECCS) discharge into of one hour. (Immediate notifications (2)If the Lacrgency Notification the reactor coolant system as a result of made under this paragraph also satisfy System is inoperative, the licensee shall a valid signal.

the requirements of paragraphs (a)(2) make th'e required notifications via (v) Any event that results in a major and (b)(2) of 6 20.403 of Part to of this commerical telephone service, other loss of emergency estensment c.h' apter.)

dedicated telephone system, or any capsbility, of fsite tr.sponse capability, or (v) Any event requiring the transport other method which will ensure that a communications capability (e 3.,

of a radioactively contaminated person report is made as soon as practir.al to significant portion of control room to an offsite medical faciitty for the NRC Operations Center.s indication. Ernergency Notification treatment.

(3)'Ae litansee shau notify the NRC Sys e or offsite otification e e ).

g threat to the safety of the nuclear the health and safety of the public or ap r a e State orI a enci and not later than one hour after the time the pownplant a sign scandy hampen she omne penonnel. w pmkchn of b i ensee dederes one of the Emergency personnelin the performance of duties enyhonment, for which a news relene necessary for the safe operation of the is planned or notification to other nuletat powerplant int.luding fires, toxic government agencies has been or will be (4) When ma a report under gas releases, or radioactive releases.

made. Such an event may include an aragraph(s (3 o this section.the (2)TourllourReports.lf not te drted onsite fatality or inadvertent release of is radioactively contaminated materials.

(i e Emerge Class declared: or

[ctQ be i ns a

yth (ii) Either paragraph (b)(1), "One.Ilour NRC as soon as precucal andin su (c) followup Nolificofion. With R port." or parsgraph (b cases, within four hours of the nspect k the telephone notificadona Rtport." as the paragrap)(2),' Tour flour h of this acetion occurrence of any of the following made under paragraphs (a) and(b) of rsquiring notification of the Non-(l) Any event. found while the reactor this section,in addition to making the Emergency Event.

Is shutdown. that, had it been found required initial notification, each (b) Non EmerFency Events. (1) One-while the reactor was in operation.

licensee, shell during the course of the Hour Reports. lf not reported as a would have resulted in the nuclear ever.t:

feclaradon of an Emergency Class powerplant, including its principal (1)Immediately report (1) ny further ander paragraph (a)of this section,the safety barriers, bein6 seriously degraded degradatior in the level of safet

of the icensee shall notify the NRC as soon as or hing in an unanalyzed condition that plant or other worsening plant '

irectical and in all cases within one significantly compromises plant safety.

conditions,includmg those that require yo the occurrence of any of the (ii) Any event cr condition that resulta the declaration of any of the Emergency 00 nr in manual or automatic actuation of an. Classes

if such a declarntion has not (t)(A)'Ihe initiation of any nuclear Engineered Safety Feature (ESF).

been previously made, or (ii) any change

>lant shutdown required by the plant's including the Reactor Protection System I"" '"' " "8'"*#

rechnical Specifications.

(RPS). Ilowever, m.*ustion of an ESF.

W) a terminsuon of the Emugency (D) Any deviatinn imm the plant's including the RPS aat results from and O'"'

Technical Specifications authorized is part of the preplanned sequence sursuant to i 50.54(a) of this part.

during testing or reactor operation need (2) /mmediately reporte (i) the resulta (11) Any event or condition during not be reported.

of ensuing evaluations or assenments of spe:stRn that results in the condluon of (iii) Any event or condition that alon, plant conditions (ii) the effectiveness of he nuclear powerplant. induding tia could have prevented the fuifillment of respoase or protective measures taken.

irincipal safety barriers, being seriously the safety function of structures or and (iii) Information related to plant tegraded; or tesults in the nuclear systems that are needed to:

behavior that is not understood.

owerplant being:

(A) Shut down the reactor and (3) Maintain an open, continuous (A)In a unanalyzed condition that maintain it in a safe shutdown communication channel with the NRC ignificantly compromises plant safety; condition.

Operations Center upon request by the (B)In a condition that is outside the (B) Remove residual heat.

NRC.

esign basis of the plant: or

)

n I the release of radioactive Dated; et Wuhington, DC this sad day of

'o d.w ee p

. s,.

4 w o ae.a.,or (D) Mitigate the consequences of an August, tems.

w NaC by twened epwouse sedear pown accident.

For the Neclear Regulatory Conunlesien.

- a"**d el****e la 84 shanner. in (iv)(A) Any airborne radioactive Semel J.ChHii,

- - "an*. l as ans, I se eaa. I sama end i rsst.

rma rekne that exceeds 2 times the M N""*".,,.7"."u*,i,er er die Nec applicable concentrations of the hmite SectoryofW casuniuina

*dd"*"d

er.-inn a 8pecnied in Appendix B.Toble 11 of Part l'* 8"*"" r#'d *** **==l perenou c

,is1 silasi assa 20 of this chapterin unrestricted areas, aussa coon resem 1

APPENDIX E 10 CFR 50.73 INCLUDING STATEMENT OF CONSIDERATIONS Published in the Federa/ Rogister on July 26,1983 (Vol. 48, No.144, pages 33850 33860)

NOTE:

This Fodorat Rogister notice does not provide a current and correct version of 10 CFR 50.73, which has been amended several times since 1983. Its purpose here is to present the Statement of Considerations, which explains the basic reporting requirements of 10 CFR 50.73.

NUREG 1022, Rev.1

i 83850 Federal Rodelse / Vcl. 43. Nr 144 / Tuesday. July 2a.19ss / Rules and Regulations i

1 Final rule, gl. RBIesteldag imidaden W Nuclear Plant Rehabany Date susseansm W Conunission is amending i

H8 N8tl*Uon8 to #98sm ee MPening d f rtigoft te la t a y

o tionalexperience at nuclear power nuclear power plant licenseet.On p ents by establishing the Lloensee Event Report (LER) system W final January so,1980 (45 F1t 6793). the NRC published an Advance Notice of rule is reeded to codify the LER pmped Rderuding ht dochbd 'h

- PU"* nquimments in order to NPRD system and inrited public establish a e le est of requirements comment on en NRC plan to makeit thate a operatingsuelear mandatory. Forty four letters wm

de a only received in enponw to the advanced

('

g a',"" *"w=3'"N g'""r, i

nwe pian new two wu.han.e

, sed mandatory onb grounds Nt reporting the v -

that denne the events 4

and situations that must be reported, of relisbuity data abound not be made a 3

and willdeAne theinformation that

",g

,g,,

- inmet be provided in ensk sport, h

904 W alm s#veoms eAm Jamnary1.1966.W decided that the requirements for incorporenen by refeo os of certain reporttag of opwetlanal experlease dets

)

pubtestons listed in we regulations is o,eded mejor revision and approwd b l

l approved by the Director of the Fedwel development of aslategrated l

l Register se d JanneryL1ses.

OperationalExperience Reporting i

pon rusmese weponsnavioer coortAcn (IOER) system The IOERsystem would l

Frederick J. Hebdon. Chief, program have combined, modihed, and made Technology Branch.Ofhoe for Analysis mandetory the adsting Lloonsee Event and Evahtion of OperationalData.

Report (IJ!lR) system and the NpHD U.S. Nuclear Regulatory Comsdasion, systea SECY 80-8078 discusses the Washington, D.C. 306tes Telephone (301) IDER system i

ess-44so.

As a result of the Connelmlen's approval of the concept of anIOER system, the NRC published another 1

)

1. Background

advance notice on january 14.1981 (46 l

On May 6.1982, the NRC published in hy e NR n o rations l

the Federal Regleter(47 FR 19643)* a experience data and dessibed the i

4 Nouce of pmpond Rul===We that deficiencies in the existing LER and would modify and codify the existing NpRD systems.

Ucensee Event Report (IJut) system On June a.1901, the Institute of Interested persons wen invited to Nuclear power Operations (INpO)

{

eubian wHnu cmaments to se announced that becaese ofits role as an ary of es,Cannimim Wy &

active user of NPRDs data it would test. Nurnerous coennents wwe assume moponsibility for management received. Aftw considwouon d b comments and other factors involved, pn dgf th a

the Commiselon has amended the criteria that would be usedin its proposed requirements published for management audits of member utilities public comunent by clarifying the scope to assen h odequacy of participation and content of the seguirements, I" O'

'W""'

i particularly the criteria that denne i

whloh analevents unust be N two principaldenoinclu eat had previously made the NpRD systein

,,pn wwe thbuste source of reliability data en ined i

W meMy M 6e ommments on 6e ability ofits committee proposed rule (1)Qastioud the management structum to provide the meaning and latent of the wineria that numany hchnica direcem ad a low l

dehned the events which mustbe level dpudcipuen by b anda.W wported,(2) questioned the need for commianau and ecdone byINp0 e of Mpwdng owtain speclAc Te need f.

provided a_ basis for conSdemos that even..dts),m.non.d

.,se,,,

,,ad s, wuCtaan naoutarony can.inafwman a.iwowdbe

,,,,,,,,,,,,,,,,,,i,,,,,,,,

CotIRA10000N required to be included in an LER.

management and fundias of 8'*8

8 *f he modos discunem no withinINp0 should overcome the l

it CpH Pwts to and 50 c==enie'in a deiait p,.vio. dmoen. nm.awd wa i

I L38'"*" E * # N'Pt8Y8'"#

icee6 er the dommanu we e ed bis fee punc $ 7,,*,,

g

&essocvt Nuclear Regulatory wYT,N*$w"m

,6 organisations. Further, with INp0 j

Compnisalon.

.on focusing upon a utility's participation in

redecal Regletee / Vcl. 48. th.144 / Tu:sday. July 26, 1983 / Ruli. end Regulations 33831 NIEDS as a specific evaluation comprehensive Integrated analytically.

2. Four commenters felt that the level parameter during routine management versstile system.

of effort would be increased but not and plant audit acuvities, the level of De Brookhaven Study, published as

significantly.

utility participation, and the'refore, the DNL/NGEG $1600. NUREQ/C8 3200,

3. One commenter felt that the quality and quanuty of NPRDS data, discusses data collection and storage proposed rule would have a minimal should sigmficantly ini:resse. llowever.

procedures to support multivariate, effect on the level of effort required.

the Commission will continue to have an multicase analysis. Whue the range of 4.Two comtnenters felt that the active role in NPRDS by participating in reactor configurations in the U.S.

proposed rule w ould significantly reduce an NPRDS User's Group, by periodicauy nutlest industry presents some the number of1.ERs filed.

enessing the quality and quantity of methodological and interpretative 5.nirteen commenters endorsed the informauon available from NPRDS. and problems. these difficulues should not objective ofimproving LER teporting but by auditing the timely evallab!11ty of the be insurmountable.no Commission felt that changes in the proposed rule information to the NRC-belleves that the NRC should have as a were needed.nese commenters did not Since there was a likelihood that specific objective the development, directly address the resource issue.

NPRDS under INPO direedon would demonstration, and implementatJon of

6. Five commenters endorsed the meet the NRC's need for tellebility data. an integrated system for collecting and proposed rule and/or felt that it was a it was nolonger necessary to proceed anel operational data that will significant improvement over the with the IOERS. llence, the coUection of empoy e predictive and analytical existing reporting requirements, detailed technical.ducriptions of potential of mtalticase, multivariate Based ou these commtnts and its own significant events could be addressed in analyses. Accordingly,the staff has assessment of the impact of tble rule, the a separate rulemaking to modify and been directed to undertake the work Comminion has concluded that the codify the edsting LER reporting necessary to develop and demonstiate impact of this rule will be no greater requirements. See SECY 8t-494 for such a cost. effective integrated system than the impact of the existing LER additional details concerning IOERS.

of operational data collection and requirements, and this rule will not flowever, the Commission wishes to analyses.

place an unacceptable burden on the I

make it expliody clear that it is relaxing If the design of the system affected licensees, the reporting requirements with the demonstratu that nch a systun ia g,j,gj,,,3j g,fy,,, g3, y,gg gyj, expectadon that sufficient utility feasible and cost. effective, development p

participation, coopersuon. and support (f 50.yJ) and the immediate Nohfication of the NPRD system will be forthcoming.

houl c mp d

y1 Rule (f 50.y2/

If the NPRD system does not become As a parallel activity to the operational at a satisfactory levelin a III. Analysis of th=aats preparation of 6 50J3. the Commission reasonable time remedial action by the Commluton in the form of additional ne Commission received forty.seven is amendingits regulations (i 50J2)

(47) letters commenting on the proposed which require that Ucensees for nuclear i

o tNr$

.thePIlfC rule. Copies of those letters and a power plants notify the NRC Operations published an advanced notice (46 FR detailed analysis of the comments are Center of sigmficant events that occur at 49134) that defernd development of the available for pubucinspection and their plants. On December 21.1961. the IOER system and sought public copying for a fee at the NRC Public Commission published in the Federal i

comment on the scope and content of Document Room at 171711 Street. NW.,

Register a proposed rule (46 !? 61894) l the LFR system. Six comment letters Washington. D.C. A number of the more that desenbed the planned changes in were received in response to this substantive issues are discussed below, l 5012.

al ter Mce ANPRM. All of the comments received lJcenserResourogre accompanying the proposed IIR rule were reviewed by the staff and were considered in the development of the Of particular concern to the (i.e 5 50J3) stated that additional proposed IIR rule. See SECY 82-3

for Commission was the impact that the changes anticipated to i 50J2 would be additional details.

proposed rule would have on the made but they would be "' ' ' largely Rio rule identifies the types of resources used by licensees to prepare administrative and the revised i 50J2 reactor events and problems that are IIRs.ne Commission's goal was to would not be significantly modified not believed to be significant and useful to assure thatlhe scope of the rule would would it be published again for public the NRC in its effort to identify and not increase the overalllevel of effort comment." Several commenters resolve threats to public safety. It is above that currently required to comply disagreed with this conclusion.

designed to provide the information with the existing IIR requirements.

De commenters did, however, agree necessary for enginnring studies of Thirty letters of the 47 received with the Commission's position that operational anomalies and trends and contained comments on the ovnall loconsistencies and overlapping patterns analysis of operaticnal acceptability of the proposed rule or requirements between the two rules l

l occurnaces.b same information can commented directly on the question of need to be eliminated.

also be used for other analytic scope and/or resources associated with he Commission has carefully procedures that will sid in identifying the proposed rule.ne views of the reviewed the proposed requirements in accident precursors, commenters can be characterized as the LIR and immediate Notification na Commission. believes that the follows:

ruleo and has concluded that although NRC should continue to seek an

1. I'Ive commenters felt that the scope charges to both have been made improved operational data system that and level of effort would be greatly (lartely in response to public comments) will maximize the value of operationel expanded by the proposed rule.

to raarify the intent of the rules, the data.ne system should ancompass and Estimates included an increase of 100 or'ginalintent and scope have not been integrate operational data of events and man years for the entire industry, an agnificantly changed. nerefore, the prob!em sequencas identified in this increase of three times the current effort. Commission has concluded that these rule. NpRDS data, and such other and an increen of $100.000 and 2 man-two rule: r.eed not be published again information as is required for a years annually for each plant.

for public comment.

33a52 rederal Regletae / Vol. 4a. N2,144 / Tuesday, Inly 26, 1963 / Rul:s end Regul:tions Engineering /udgment IIRs).%ey noted that reports of RPS this rule, but did not change h original in the rederal Register pouce that actueums are already reported to the wope of intent of the requirementa. In eccompanied the proposed rule, the NRC la the Monthly Opereting Status addition,in order to make the Commission stated that licensee's Report, as well as telephoneo to the requirements in il 5072 and 50J3 more NRC Operations Center.

compatible, the order (i.e. numbering) of enginaring judgment mey be used to in addition, the Lasutute of Nuclear the criteria in i 5013 bas been changed.

decide if an event is reportable. Several Power Operations (INPO) analysed the ne changes are noted in the discussion comm ntets expressed the belief that or+ month pen. actor scrams during a of each paragraph below, I9"'"CY "I "

some wording should be added to the l'inally, conforming amendments are od.Ris analysis rule of reflect that the NRC will also me judgm:nt in enforcement of this indicated that an average of 65 reactor being made to various sections of Parts trips would be reportab.e each month 20 and 50in order to reduce the regulation where the licenen is under the proposed rule.1NPO equated redundancy in reporting requiremente requnted to use engineering judgmsat this to 600 additional 1ERs per yeer f or ' that apply to opersting nudear power ne Commission tielieves that the IIR all cmma y opwating plants, or plants. In genersl thm amendments rule adequately discusses the need for approximately 32 man-yeare of will r, quire th'at of g' (d *Ep1 addiuonaleffort for au the currently t Ucensees that have an Emergency

,e gment e neept p" sting plants band upon the Notification System (ENS) make the its indudes the recognidon of the ammptim that each 1ER requires 100 reports required by the subject sections exist:nce of a ressonable range of int:rpretation regarding this rule, and

"" [h urs ieffort to prepare and via the ENS. All other licensees wiu fe wieo8" tuati incl ding ac rt a.

A tr ri e op o riste1 RC ses a

'8i the need for flexibility in enforcement freq d

unociated with esIo a thi rInceptis ($

sYety e ve eo en tare suinc!ently dear and that additional significance.In additio~n If the ESFs are a

the explicit guidance is not necessary, being challenged during ruutine appropriate RegionalOffices Neportins Schedul, transients, that fact le of safety

3. lloiders of licenses to operate a nudear power plant submit the written in the Federal Register nouce that d ilu e

i o doe not accompanied the proposed rule, the.

agree with the eettmate that e'ach IIR reports required by the subject sections in accordance with the procedurea Commission stated that 11 had not yet submitted for a routine reactor trip described in i 50LM(b).

dreidedif the reports should be would require, on the averoga.100 man-ne critals e ntained in the subject submitted in fifteen days or thirty days hours to prepara and analyza.ucensees sections which defme a reportable event following discovery of a reportable are already required to make internal have not been modi 5ed.

evsnt. Many commenters stated that the evaluation of and document significant Similar changes are also planned as time frame for reporting IIRs should not events,induding reactor trips.

b3 less than tbtrty days after the Derefore, the incrementalimpact of part of eurent activides to make more discovery of a reportable event.

preparing and analyzing the IIR should substandve changes to Part 21 One commenter estimated the impact be significantly leis than 100-man hours, l 50.55(e), and i MJ1.

of a regulrement to submit a report in addition, the actualincrease in Nonconservatire Interdependence sooner than 30 days following discovery burden would be offset by reducuens in Several commenters expressed of a reportable event would be an the burden of reporting less significant difficulty in understanding the meaning increne of approximately 40 man years events that would no longer be per year for the currently operating reportable, of the phrase *nonconservauve plants. In eddidon the commenter interdependence" as used in the estimated tht if a summary report wer, Coonfination With Othe Reporting proposed i 5053(a)(3).The wording of clso required the reporting burden Requirements i 50J3(a)(3)(! $0J3(a)(2)(vil) of this would increase an addluonal12 man Several commenters noted that the final rule) has been changed to eliminate years for the currently operating plants, proposed rule did not appear to be the phrase "non conservative in response to these comments, the coordinated with other existing interdependence" try speciDeally Commission has decided to require that reporting requirements. and that defining the types of events that should IIRs be submitted within 30 days of duplication of licensee effort might be reported. The revised paragraph does discovery of a reportable event or result.Dey recommended that LER not, however, change the intent of the situation.

reportl be consolidated to eliminate original paragraph.

- j *th **I'\\\\"3 Sobotage and Threats of Violence

*tI* O*PI Reporting of Reactac Trips g,

S:ction 5073[s)(1) of the proposed

%e Commission has reviewed -

Several commenters noted that the ruli(l 50J3(a)(2)(iv)of the finalrule) existing NRC reporting requirements security-related reporting requirements required repoving o( any event which (e.g 10 CFR Parts 20 and 21. I 50.55(e),

of I $01s(a)(6)(l 50J3(a)(2)(lit) of this resulte la an unplanned manual oc l 50J2. I 5053. I y3J1. and NUREG.

final rule)) were already contained in autsmatte actuation of any Engineered 0654) endhas attempted, to the extent greater detsu in to Cat nJt.For

. Saf;ty Feature (ESF)lncluding the practicable, to eliminate redundant instance. I nJ1 requires an act of Resctor Protection System (RPS). Many reporting and to ensure that the various sabotage to be reported immediately, v

commenters agreed that these avents reportingreq61rements are conalstent.

followed by a written report within 15 should be trended and analyzed.but hjany of the changesin the finalIIR days.He proposed rule would have disagreed that they deserve to be rule are as a rere of this effort.nese required an IIR to be filed within 30 singled out es events of special changes roeulted in extensive revisions days. Although distribution of reports is sigifficance (i e dvente reportable as in the we ;ng of criteria contained in somewhat different. redundant reporting

j Teder:1 Regi:t:r / Vol. 48. No.144 / Tuesdey. July 2.19a3 / Rules and Regulations 33853 would hcve occurred.ne commenters in NPRDS as an alternative. it is our Several commenters argued that h recommended that the Commission understanding. however, the NPRDS will inclusion of the requirement that the ensure consistency between ll 273 soon adopt the Ells system titles, so a licensee perform an engineering and y3.71.

distinction shoulta no longer exist. In.

evaluation of certain events at the sisfPs in response to these comments the addition. IIRs frequently include request appeated unjustified and would ComtrJssion has deleted the reporting of systems that are not included in the /m add substantially to the burden of aabotage and threats of violence froto scope of NPRDS (i.e., an NPRDS syst reporting.ney argued that the licensee 150,73 because these situations are identification does not exist) whue EIIS.

should be required to submit only the adequately covered by the reporting on the other band. includes all of%

specific additional information required requirements conteined in i 73.71.

systems commonly found in cornmercial for the necessary erigineering evaluation

& acuation of / looms or Buildings nuclear power plants. Further. NPRDS rather than to perform the evaluation.

includes ordy 39 component identifiers ne rule has been modified to require Many commenters stated that the (e.g., valva, pump). ne Commission on) the submittalof any necessary reporting of in plant releases of believes that this limited number does ad itionalinformation requested by the radioactivity that require evacus tion of not provide a sufficIently detaued Commission in writing.

ludividual rooms (i En(s)(T)in the description of the component function ptaposed rule or (I mn(s)(2)(x) of this involved.

IV. Specific Findings final rule) was inconsistent with the general thrust of the rule to require function of TolledComponents and Overview of the L.EJl System reporting of significant events. ney Mtus o/ Redundant Comlwents When this fMalIIR rule becomes noted that minor spius, small gaseous Many commenters said that effective the IIR will be a detailed weste releeses, or the disturbance of information required in (l 273(b)(2) (vi) narrauve description of potentially contaminated particulate matter (e.g.,

and (vil)of the proposed rule should not significant safety events. By describing dust) may all nquire h temporary evecuadon of Individual rooms until the be a requirement in the IIR.ney in detsu the event and the planned airborne concentrations decrease or argued that this information is readily correct!ve action. It will provide the until respiratory protection devices are available in documenta previously basis for the careful study of events or uultzed. ney noted that these events submitted to the NRC by licensees and conditions that might lead to serious are avadable for toference.

accidents. lf the NRC staff decides that are f airly common and should not be reportable unless the required ne final rule (i En(b)(2)(1)(G)) has the event was especially significant beenL- 'ified to narrow the scope of frotn the standpoint of safety, the sta!!

evacuation affects the entire facility or a melor portion thereof.

the information nquested by the may request that the licensee provide la responw to these comments the Commission.

additionallaformation and data wording of this criterion (i En(s)(2)(x)

While this generalinformation may be associated with the ennt.

in the final rule) has been changed to available in I censee documents

%e licenace will prepare an1ER for significantly narrow the scope of b pnviously submitted to the NRC. tha thou events or conditions that meet one critedon to include only those events Commission believes that a general or more of the criteria contained in which significantly hamper the ability of understan of the event andits i 50.n(s).ne criteria are based site persennel to perform safety-relsted significance e ould be possible without primanly on the nature, course. and activides (e g, evacuation of the main reference to additional documentation consequences of the event.nerefore, control room).

which may not be readily or widely the finalIIR rule requires that events avausble.particularly to the public.

which meet the criteria are to be Energy Industry identificatiov System ne Commission continues to believe reported regardless of the plant Many commenters noted that the that the licenses should prepare an IIR operating mode or power!evel and requirement to report the Ene.gy in sufficient depth so that regardless of the safety significance of Industry identtfication System (Ells) knowledgeable readers who are the components systems, or structures component function identifier and conversant with b design of involved. In trying to develop critena for system name of each component or commercial nuclear power plants, but the identification of events reportable as system referred to ln the IIR are not familiar with the detaus of a IIRs. the Commission has concentrated description would be a significant particular plant, can understand the on the potentialconsequences of the burden on the licensee.

general characteristics of the event (e.g event as the measure of significance.

ney suggested instead that the the cause,the significanca ther Therefore, the reporting criteria. In NPRDS component identifiers be used la corrective action). As. suggested bythe general, do not specifically address place of the 121S component identifiers commentars, more detaued information classes of initiating events or causes of which are not yet widely used by the to support engineering evaluations and the event. For exampla there isYo indus case studies willbe obtained.as requirement that all personnel errors be na mmission contmues to believe needed, directly from the previously reported. However, many nportable that 121S system names and component submitted licenses documents.

events willlavolve or have been function identiflers are needed in order initiated by personnel arrors.

I

8 "## N that LIRs from different plants can be Finally.it abould be noted that compared.We do not.however, suggest ne overview discussion of the licensees are permitted and encouraged that the E1IS Identifiers be used proposed rule contains the following to nport any event that does not racet throughwt the plant.but only that they statement:"If the NRC staff decides that the criteria contained in i 50.n(e), if the be added to the IIR as it is writtaa. A the event was especially significant licensee believes that the event might be simple. tnexpenalve table could be used - from the standpo.nt of safr.ty,the staff of safety significance, or of generic to translate plant identiflers into may request that the licenses perform interest or concern. Reporting

.l equivalent ERS IdentiBers.

an engineering evaluation of the event requinmente aside, assurance of safe no Commission considered the and describe the results of that operation of all plants depends on system and component identthrs used evaluation."

accurate and complete reporting by each

t 33f154 rederal Register / Vd. 48. N:.144 / Tuesday, July 26, 1983 / Rules cnd Regul:tions lic:nsee of all events having potendal consequences of an event (e s., at the accident (e p., containment isolation.

sity significance.

discreuon of the licensee as part of a emergency filtration). Hence, minor forestoph-by.Pompoph Explanodon of plarmed procedure or evolution).

operauonal events involving a specific ths LER Ru/,

Sections 5033(a)(2)(v) and (vt) component such a valve packing leaks.

(proposed I 50.73(a)(2)) require reporting which could be considerd a lack of The significant provisions of the final of:

control of radioactf ve material, should LIR rule are empleined below.ne not be reported under thia parapaph.

explanstion follows the order in the (v) Any event or condiuon that alone could System leaks or other similar events pro >osed rule.

have prevented the fulfdtment of the ufety may, however, be reportable under other pct: graph 50.73(a)(2)(lv)(pmpowd functon of structurn or systems that an pangraphs.

pirspaph 50.73(s)(t)) requires reporting needed to:

It abould be noted that there are a of:"Any ennt or condluon that resulted IAl Shut down the nector and maintain it limited number of single-train systems la manual Automatic actuation of any in a safe shutdown condition; that pedonn sdW funcuana (e4,6e

ty Feature (ESP)

(B) Remove restdual heat Engineerea including the deactor protection System (C) Contml the relun of ndioactin

@ henum Man @cdon Sydem e

"" d 'l

'I (RPS). Ilowever, actuation of an ESF' (D) Mitisite the consequences of an single train would prevent the incl: ding the PJ'S, that resulted from accident.

fulfdlment of the safety function of that and was part of the preplanned (vil rvents mvered in parssreph (s)(2)(v) system and, therefore enust be reported s:quence during testing or reactor of this section may include one or mor*

even though the plant Technical operation need not be reported.

personnel errors, equipment failure s, e nd/or Specifications may allow such a his paragraph requires events to be dieoonry af deetsn. analyele, fabrica non, condition to exist for a specified limited reported whensver an ESF actuates coratruction, ud/or procedural 1ength o! urne.

cither manuaU or automatically, inade quacies. llowever. individual it should also be noted that,if a regardlere of p tnt status. It is based on component fallures need not be reported the premise that the ESFs are provided P"""*" thl' P"'a5FeP if redundant poterPlally serious human error 14 made b

13 mitigate the consequences of a equJprnent in the same system wu operable that could have prevented fulfdiment of and evallable to perfonn the required safety a safety function, but recovery Iactors significant event and, therefore: (t) %ey functi n.

resulted in the ermt being corrected, tne should work properly when caued upon, end (2) they should not be challenged ne wording of this parapsph has ermt is still reportable.

frequently or unnecessarily.ne been changed imm the propssed rule to

%e Commission recognises that the Commission is interested both in events make it easier to read.%e intent and application of this and other parspaphs where an ESF was needed to mitfaste scope of the paragraph have not been of this section involves the use of the consequences (whether or not the Ch*Dged, engineering judgment on the part of cquipment performed properly) and De intent of this parsgraph la to licensees. In this case a technical cvnts where an ESF operated capture those events where diere would ludgment must be made whether a unnecessardy.

have been a fauure of a safety system to fal!ure or operator action that did

" Actuation" of multichannel ESF properly complete a safety function, actuaUy disable one train of a safety Actuation Systema is defined as regardless of when the failures were system, could have, but did not, affect a actuation of enough channels to discovered or whether the system was redundant train within the ESF system.

complete the minimum actuation logic needed at the time, if so, this would constitute an event that (i.e cctivation of sufficient channels to nis parapaph is also based on the

could have prevented" the fulfillment c:use activation of the ESF Actuation assumption that safety-related systems of a safety function. and, accordingly.

Syst:m).nerefore, single channel and structures are intended to mitigate must be reported.

actu:tions, whether caused by failures the consequences of an accident. While if a component falle by an apparently or ctherwise, are not reportable Lf they I 50.73(a)(2)(iv) of this final aule applies randcm mechanism it may or may not do n:t complete the minimum actuation to actual actuations of an ESF.

be reportable if the functionally logic.

I 50.73(a)(2)(v) of this final rule covers redundant component could fau by the Operation of an ESF es part of a en event or condition where redundant same mechanism. Rep s.ingis required pt:nned operational pmcedure or test structures, components, or treins of a if the fauure constitutes a condition (e4, startup testing) need not be safetv system could have failed to where there is reasonable doubt that the reported.llowever,if during the planned perf a their intended function because functieaally redundant train or channel cperating procedure or test, the ESF of: sne or more personnel ermrs, would remain operational untilit cctuates in a way that is not part of the including procedure violations; completed its safety function or is pl:nned procedure, that actuation must equipment fauures; or design, analysis, repaired. For example,if a pump in one be repcried. For example,if the normal fabrication, construction, or procedural train of an ESF system fails because of re:ctor shutdown procedure requires deficiencies.%e event must be reported improperlubrication and engineering that the controlrods be inserted by a regardless of the situation or condition judgment indicates that there is a manual reactor trip the reactor trip need that caused the. structure or systems to reasonable expectation that the n:t be reported. Ilowever. if condidons be unavailable, and regardless of functionally redundant pump in the develop during the shutdown that whether or not an alternate safety other train, which was also improperly require an automatic reactor trip such a system condd have been used to perform lubricated, would have also failed reactor trip must be reported.

the safety function (e.g High Pressure before it completed its safety function.

The fact that the safety analysis Core Cooling failed but feed-and-bleed then the actual (suure is re riable and assumes that an ESP will actuate or law Press Core Cooling were the potentialfauure of the unctionally c;tomatically during certain plant available't6 p vide the safety function redundant pump must be discussed in conditions does not eliminate the need ofsore co91 Lng).

the L.ER.

13 report that actuation. Actuations that The applicability of this parapaph For safety eystems that include three need not be reported are those initiated includes those safety systems designed or more trains, the failure of two or more for reasons other than to mitigate ths to mitigste the consequences of an trains should be reported if. In the

i rederal Register / V:1. 4a. No.144 / Tursday. July 26,1983/ Rt,:.es end R:gulati:ns 33855 Judgement of the licenue, the functional (D) Mitigate the consequences of an within the time limit specified in the capabihty of the overall system was a ccide nt."

Techrdcal Specifications. the scuon jeopardared.

This paragraph has been changed tb need not be reported under this interaction between systems, clanfy the intent of the ph ase, paragraph. However. if, while the train

/

particularly a safety system and a non.

nonconservative interdependence."f or component is out of service, the safety system. is also included in this fiumerous comment letters expressed licensee identifies a condition that could criterion. For example, the Commission difficulty in understanding what this have prevented the whole system from is incressmgly concemed about the phrase meant: so the parsgraph has performing its intended function (e g..

effect of a loss or degradation of what been changed to be more specific.ne the licensee finds a set of relays that is had been neumed to be non. essential new paragraph is nastower in scope wired incorrectly). that condition must inputs to safety systems.nerefore, this then the original paragraph because the be reported.

paragraph also includes those ceses term is specifically defined. but the Section !A73(s)(2)(i)(proposed where a service (e.g. heating.

besic intent is the same.

1 TA73(s}(4)) requires reporting of; ventilation, and coohng) or input (eg This paragraph requires those events

.gg) g, go,p,gg,,,g,3y g,gg,,,

g compressed alt) which is necessary for to be reported where a single cause plant shutdown required by the plant's reliable or long-term operation of a produced a component or group of Technical Speedicaum w safety a ster. La lost or degraded. Such components to become inoperable in loss or egradation is reportable if the redundant or independent portions (i.e

,I

']

{ I'd Y g' proper fulhllment of the safety funcuon trains or channels) of one or more p

is not caruiot be assused. Failures that systems having a safety function.nese

,,(C) Any deviation from the plant,s events can identify previously Technical Specifications authonzed affect inputs or sermes to edstems that unrecogulted common cause failures pursuant to i 50.54(x) of this part.,

have no safety function ace not be repwted.

and systems interactions. Such fauures his paragraph has been reworded to can be simultaneous failures which more clearly define the events that rnust Finally the Commission recognizes that the licensee may also use occur because of a single initiating be reported. In addition, the scope has engtneenng judgment to decide when cause [1.e., the single cause or been changed to require the reporting of penonnel actions could have prevented rnechanism serves as a common input to events or conditions " prohibited by the fulfillment of a safety function.For the failures): or the failures can be plant's Technical Specifications" rather example, when an individual improperly sequential (i.e cascade failures), such than events where "a plant Technical as the case where a a le component Specification Action Statement is not operates or maintains a component, he failure results in the la ute of one or met." This change accommodates plants might conceivably have made the same error for all of the functionally m re additional components.

that do not have requirements that are ifhe To be repoytable, however, the event specifically defined as Action redundant components (e.batable or failure mdst result in or involve the Statements.

incorrectly calibrates one f ailure of independent portions of mom his paragraph now requires events to amplifier in the Reactor Protection than one train or channelin the same or be reported where the licensee is System.he could conceivably Memnt systune.Fw example.if a required to shut down the plant because incorrectly calibrate all bistable amplifiers). llowever, for an event to be

'*"".C""diuon caused components the requinments of the-Technical in Train A and 'B of a single system Specifications were not toet. For the reportable it is riecessary that the to become Inoperable, even if additional purpose of this pangrapk* shutdown" actions actually affect or involve trains (e.g, Train. 'C") wne sull is defined as the pomt in time where the components in more than one trala or available, the event must be reported. in Technical Specifications require that the channel of a safety system, and the result of the actions must be undesirable addition, if the cause or conditio,,n plant be in the Drst shutdcwn condition cauwd c mpents inTrain A of m required by a !)miting Condition for from the perspective of protecting the system and in Train B" of another Operation (e g hot standby (Mode 3) for health and safety of the public.The system (f.e., a train that is aseumed in PWRa with the Standard Technical components can be functionally the safety analysis to be independent) to Spehumsbif the condidonis redundant (e.g., two pumps in different e,

e ust be trains) or not functionally redundant corrected before the time limit for being pott y

shut down(Le befors completion of the (e s., the operator correctly stops a pump d

n E",dif"ne sy'obm a s,,,

shutdown), the event need not be in Train "A" and. Instead of shutting the g,

T MPorted.

pump discharge valve in Train "A." he another system (i.e., tralna that an not in addition. Lf a condition that war rnistakenly abuts the pump discharge assumed in the safety analysis to be valve in Train "B ),

independent), the event need not be prohibited by the Technical Section 50.73(a)(2)(vil)(proposed reported unless it meets one or more of Specifications existed for a period of I 50.73(a)(3)) requires the reporting of:

the other criteria in this section, time longer than that permitted by the "Any event where a single cause or In addition, this paragraph does not Technical Specifications. it must be condition caused at least one include those cases where one train of a nported mn if the condition was not independent train of channel to becomo system or a component was removed discovered until after the allowable time inoperable in multiple systems or two from service as part of a planed had elapsed and the condition was independent trains channels or to evolution in accordame-'vith an rectified immedistely after discovery.

become inoperable in a system designed approved procedure, ont, a accorb-',

Section 50J3(a)(2)(if)(proposed to:

with the plant's Technica, 5 5053(a)(5)) requires reporting of:"Any (A) Shut down the reactor and Specifications. For exarn? e. if the event or condition that resulted in the l

maintain it in a safe shutdown licensee removes part of a system frvm condition of the nuclear power plant, condition.

service to perform maintenance, and the including its principal safety barriers.

(B) Remove residual heat.

Technical Specifications permit the being seriously degraded, or that (C) Control the release of radioactive resulting configurstion, and the system resulted in the nuclest power plant material; or or component is returned to service being-

4_.,

33856 Federal Registee / Vgl. 48. Ns.144 / Tt:sday, ju)y 26. 1963 / Rul:s cnd Regul:ti:ns

"( A) In an unanalyzed condluon that radioactivity levels at a flWR sir elector safety of the nuclear power plant or significantly compromised plant safety; monitor that exceeded the Technical significantly hampered site personnelin

"(D)In a condition that was outside Specification limits.

the performance of duties necessary for the design basis of the plant: or (c) Cracks and breaks in piping, the the safe operation of the nuclear power "lC)In a condition not covered by the reactor vessel, or major components in plant including fires, toxic gas releases, plant's operating and emergency the primary coolant circuit that have or radioactive releases."

procedure s."

safety relevance (steam generators.

His paragraph has been reworded to This paragraph requires events to be reactor coolant pumps, valves etc.)

include physical hazards (internal to the reported where the plant. including its (d) Significant welding or material prtncipal safety barners, was seriously defects in the primary coolant system.

bant) to personnel (e.g electrical fires).

l addiuon in response to numerous degraded or in an unanalyzed condition.

(e) Serious temperature or pressure commeats, the scope has been narrowed for example, small voids in systems translebts (e.g., transients that violate so that the hatard must hamper the designed to remove heat from the the plant's Technical Specifications).

ability of site personnel to perform rsector core which have been previously (f) Loss of relief and/or safety valve safety-related activities affecting plant showr. through analysis not to be safety operability during test or operation

,,g,,y' significant need not be reported.

(such that the number of operable in. plant releases must be reported if flowever, the accumulation of voids that valves or man.way closures is less than they nquire nacusuon of moms or could inhibit the ability to adequately required by the Technical buildings contelning systems important r* move heat from the teactor core.

Specificauons),

to safHy and as a neult, the abMy of p:rticularly under natural circulation (g)less of contalnment function or the operators to perform necessary conditions would constitute an integrity (e:3., contalament leakage rates esfdy functions is signWeantly uninalysed condition and must be exceeding the authorised limits).

hampered. Precautionary evacuations of reported. in addition, voiding in Section 60.73(a)(2)(lil) (proposed instrument lines that results in an I $0.73(a)(6)) requires reporting of: "Any rooms and buildings that subsequent erroneous indication causing the natural phenomenon or other external evaluation determines were not required operator to significandy misunderstand condition that posed an actual threat to need not be reported.

the true condition of the plant is alsa en the safety of the nuclear power plant or Proposed i 50.73(a)(8) was intended to unanalyzed conditibn and must be significantly hampered site personnelin capture en event that involved a

reported, the performance of duties necessary for controlled release of a significant ne Commission recognites that the the safe operation of the nuclear power am6unt of radioactive material to offsite lic:nsee may use engineering judgment pla nt."

areas. In addition. "significant" was and experience to determine whether an his paragraph has been reworded to based on the plant's Technical unanalyzed condition existed. It is not make it clear that it applies only to acts Specification limits for the release of intended that this paragraph apply to of nature (e.g., tornadoes) and external radioactive material. However, this minor variations in individual hatards (e.g., railroad tank car section has been deleted because the p:rtmeters, or to problems concerning explosion). References to acts of reporting of these events is already single pieces of equipment. For example, sabotage have been removed because required by I 50.73(a)(2)(l) and i 20.405.

at any time, one,or more safety.related they are covered by 6 73.n. In addition.

Section 50.73(a)(2)(vill) and (Lx) components may be out of service due threats to personnel from intemal (proposed I $0.73(a)(9)) require reporting to testing. maintenance, or a fault that hatards (e.g., radioactivity releases) are of:

has not yet been repaired. Any trivial now covered by a separate paragraph single failure or minor error in (150.73(a)(2)(x)).

(vill)(Al Any otrbome redacuvity releen performing surveillance tests could his paragraph requires those events that exceeded 2 times the applicable produca a situation in which two of to be reported where there is an actual concentrouone of the limits specified in Table more often unrelated, safety.related threat to the plant from an external U of Appendix B to part 20 of this chepter in components are out.of. service, condition or natural phenomenon, and unrestricted erves, when everaged over a Technically, this is en unanalyzed where the threat or damage challenges ume penod of one bour, conditton. l{owever, these events should the ability of the plant to continue to (B) Any liquid effluent reluw that b3 reported only if they involve operate in a safe manner (including the exceeded 2 tunes the limtung combined Co functionally related components or if orderly shutdown and maintenance of

\\ex mum pennis

, gp B

t th:y significantly compromise plant

.hutdown conditions,

che pier) et b pod d entry M s:fety.

Delicenseeis to ecideif a mving water (to unremed arvelfor en Finally, this paragraph also includes phenomenon or condiuon actuallY radionuchdes except tntium and dissolved me terial (e.g., metallurgical, chemical) threatened the plant. For example, a noble goes, when avereged over e time problems that cause abnormal tulnot brush fire in a remote area of the penod of one hour, d: gradation of the principal safety site that was quickly controlled by fire (lzl Reports submitted to the Commleston b: triers (i.e., the fuel cladding. reactor fighting personnel and, as a result did in accordance with peregraph (e)(2Xvt11) of coolant system prmure boundary, or not present a threat to the plant need thte wcuon also mut the effluest relem th3 containment).

not be reported, l{owever, a mejor forest reporting requirements of paragraph Additional examples of situations fire. large. scale flood, or major 2asogepsy*to of this chapter.

included in this paragroph are:

earthquake that presents a clear threat (a) Fuel cladding failures in the to the plant must be reported. Industrial peregraph (viii) has been changed to r:setor or in the storage pool, that or transportation accidents that clarify the requirements to report exceed expected values, that are unique ocrurred near the slie and created a releases of radioactive material.he or widespread, of that resulted from plant safety cbncern ntust also be paragraph is similar to i 20.405 but unexpected factors.

reported.

places a lower threshold for reporting (b) Reactor coolant radioactivity Section 50.73(a)(2)(x)(proposed events at commercial power reactors, levels that exceeded Technical I 50.73(a)(7)) requires reporting of:"Any The lower threshold is based on the Specification limits for iodine spikes or, event that posed an actual threat to the significance of the breakdown of the

Federal Register / Vtt. 48. Nr.144 / Tuisday, July 26, 1983 / RuW cnd R:gulati:ns 33857 licensee's program necessary to have a in a condition not analyted in the Safety "Special Reports" of the Technical r:tesse of this sire. rather than on the Atelysis Report) under reasonable and Specifications are still required.

si nificance of the impact of the actual credible alternative conditions, such er V.Rerulatory Analysis power level or operating mpde. For te ease.

Reports of events covered by example.'il an event occurred while th The Commission has prepared a i 5013(a)(tl(viii) are to be made in lieu plant was at 15% power and the same regulatory analysis for this final rule.

cf reporting noble ses re! esses that event could have occurred while the The analysis examines the costs and exceed to times the instantaneous plant was at 10M power, and, as a benefits of the alternatives considered release rate. without eversging over a result, the consequences would have by the Commission. A copy of the time period, se implied by the been considerably more serious, the regulatory analysis is available for requirement of I 20.405(s)(5).

licenses must assess and report those inspection and copying for a fee at the Paragraph 5013(b) desaibes the consequences.

MRC Pubtle Document Room.1717 H format and content of the IJA It Paragraph 50J3(b)(4) nquiree that the Street. N.W We shington. D.C. Single requires that the licenses prepare the licensee describe in the IIR any copies of the analysis may be obtained IIR in sufficient depth so that corrective actions planned as a result of from Frederick J. Hebon Chlef. Program knowledgeable readers conversant with the event that are known et the time the Technology Branch. Office for Analysis the design of commerdal nuclear power IIR la submitted. lacluding actions to and Evaluation of Operational Data, plants, but not familiar with the details reduce the probability of similar events U.S. Nuclest Regulatory Commission.

cf a particular plant. can understand the occurring in the future. After the initial Washington D.C.20555: Telephone (301) complete event (i.e., the cause of the IIR is submitted only substantial 492-4480.

4 ud be VI. Paperwork Reduction Act Statement and the se uence of enc t

s p

ntal O' ""4 Paragraph 60J3(c) authorizes the NRC ne Nuclear Regulatory Commission Paragraph 6053(b)(1) requires that the licensee provide a brief abstract staff to require the licensee to submit has submitted this rule to the Office of specific supplementallnformation Management and Budget for such d: scribing the major occurrences during beyond that required by I 6053(b). Such review as may be appropriate under the the event,includ'ng all actual information may be te utred if the staff Paperwork Reduction Act. Pub.L 96-component or e stem failures that finds that supplementa materialis

$11. The date on which the reporting c:ntributed to e event. all relevant cperator errors or violations of necessary for complete understandmg of requirements of this rule become procedurts, and an significant an unusually complex or significant effective reflects inclusion of the today corrective action la en or planned as a event. Such requests for supplemental period whk.h the Act allows for such result of the event.nis parsgraph is information must be made in writing, review.

treded to give IIR data base users a and the licensee must submit the V11. Regulator) Mexibility Certification brief description of the event in order to "9['[ft!

identify events of interest.

s tim period in accordance with the Regulatory Paragraph 50J3(b (2) requires that the mutually agned upon by the NRC staff Flexibility Act of 1980. $ U.S.C. 005(b).

the Commission hereby certifles that f

C "'

licensee include in e IIR a clear.

'"p agrap'h specific narrative statement of exsetly 3 gives the NRC's this rule will not have a significant stantial what happened during the entire event Executive Director or Operations the economic tropact on a sub.g.his hie so that readers not familiar with the authority to grant case-by-case g

g g

unde ad the e en ~ e licensee requirem t cont lne in the IIR dominant in their respective service should emphasite how systems system.nis exesaption could be used to areas and that own and operate nuclear components. and operating personnel limit the collection of certain data in utilization facilities licensed under performed. Specific hardware problems those cases where full participation sections 103 and 104b of the Atomic should not be covered in excusive would be unduly difficult because of a Energy Act of1954. as amen e.The detail. Characteristics of a plant that are plant's unique design or circumstances.

amendments clarify and modify unique and that influenced the event Paragraph 50J3(g) states that the presently existing notification (favorabl[ne narrative must alsoor unfavorably) must be reporting requirementa contained in mquimmats.

describe i 5033 replace the reporting Accordingly, them is no new.

describe the event from the perspective requirements in all nuclear power plant significant economic impact on these cf the operator (e.g. what the erstor Technical Specifications that are licensees. nor do these licensees fall saw did. perceived.underst or typically associtated with Reportable within the scope of S definition of misunderstood).

Occurrences.

ernali entities, set te in 2e Paragraph 50J3(b)(3) requires that the ne reporting requ remente Regulatory Flexibility Act or the Small IIR include a summary assessment of superseded by i 60J3 are those Business Size Standards set out in the octual and potential safety contained in the Technical Specification regulations issued by the Small Business consequences at d implications of the sections that are usually titled " Prompt Administration at 13 CFR Part 121.

cvent.%Is assessment may be based on Notification with Written Followup" 1.tst of Subjects the conditions existing et the time of the (Section 6.9.1.8) and **Ihirty Day Written Cvent.He evaluation must be carried Reports" (Section 6.9.1.9). The reporting 20 M P46 out to the extent necessary to fully requirements that have been superseded Licensed material. Nuclear power asseas the safety consequences and are also described in Regulatory Guide plants and reactors. Pensity. Reporting safety margins associated with the 1.16. Revision 4. " Reporting of Opera ting and recordkeeping requirements, cvent. An assessment of the event under Information-Appendix ATechnical Jo NARM alternative conditions must be included Specifica tion." Paragraph 2. " Reportable If the incident would have been more Occurrences." ne special report incorporation by reference. Antitrust.

severe (e.g, the plant would have been typically described in Section 6.9.2 Classified information. Fire protection.

33858 rederal Restater / Vcl. 48. N:.144 / Tu:eday, July 26, 1983 / Rul:s cnd Regulations Intergov ernmental rela tions. Nucle ar (C) Any deviation from the plant's (D) Mitigate the consequences of an pow:t plants and reactors. Penalty.

Technical Specifications authortred accident.

Radiation protection Reporting and pursuant to i 50.64(x) of this part.

(viii)(A) Any airborne radioactivity r:cordkeeping requirements.-

(ii) Any event or condition that release that exceeded 2 times the resulted in the condition of the nuclear applicable concentrations of the lirnits Under the authority of the Atomic power plant, including its principal specified in Appendix D. Table 11 of Part Energy Act of 1954. as amended, the safety barriers, being seriously 20 of this chapter in unrestricted areas, Energy Reorganizauon Act of 1974, as degraded, or that resulted in the nuclear when averaged over a time period of aminded, and 5 U.S.C 552 and 553, the p wet plant being:

one hour, following amendments to to CFR Parts (A)In an unanalyzed condition that (B) Any liquid effluent releau that 20 cod 50 are published as a document significantly compromised plant safety; exceeded 2 times the limiting combined subject to codification.

(B)In a condition that was outside the Maximum Permissible Concentration PART 50-OOMESTIC UCENSING OF dulgn buis of the plant or (MPC)(see Note 1 of Appendix B to Part PRODUCTION AND UTILIZATION (C)In a condition not covered by the 20 of this chapter) at the point of entr)

FACluTIES plant's operating and emergency into the receiving water (i.e.

procedures, unrestricted area) for all radionuclides

1. The authority citation for Part 50 (111) Any natural phenomenon or other except tritium and dissolved noble continues to read as follows:

external condition that posed an actual gases, when aversged over a time penod threat to the safety of the nuclear power of one hour.

Autnertry: Secs.1os, in 181.182.163.188.

1ee.se Stat saa,e:7.e44, ass, en on ess, a plant or significantly hampered site (ix) Reports submitted to the emended. pc. 2n as Stat. tan as amended personnelin the performance of duties C

8--6an in acmedance with (0 U.SC 2133,21n 2301,2232. 2233,223s, necessary for the safe opustion of the paragraph (a)(2)(viillof this secnon also 2238. 2282k eeca. 201. 3o2, aos, se Stat.1242, nuclear power plant.

meet the effluent release reporting 1244.124s, u amended (42 USn sett. se42 (lvJ Any event or ocodition that requirements of paragraph 30.406(a)(5) t 544e). unine otherwtw noted-resulted in manual or automatio of Part 20 of this chepter.

Section 80J ateo leeued onder Pub. l. 95-actuation of any Engineered Safety (x) Any event that posed an actual 801. sec.10. 92 Stat. 2est (42 U.S C r ast).

Feature (ESF), including the Reactor threat to the safety of the nuclear power Sectiona 60.54. Ett and to.s2 ateo leeued Protection System (RPS).Ilowever, plant or significantly hampered site actuation of an ESF, including the RPS.

personnelin the performance of duties

" e')

5 e $1 ed 123 that resulted from and was part of the necessary for the safe operation of the 122. es Sta t. s3e (42 USA 2152). Sections saso-aart she inued andee sec. In as Stat. preplanned sequence during testing or nuclear power plant including fires.

954. as amended (42 UAC 2234). Sections reactor operation need not De reported.

toxic gas releases, or radioactive E100-M.102 also tassed under sec.1s6, te (v) Any event or condition that alone releases.

St:t. 955 (42 UAC 2236).

could have prevented the fulfillment of (b) Contents. The IJcensee Event for the purpone of Dec. 223, se Stat. On as the safety function of structures or Report shall contsin:

emended (42 USA 2273), il So.10 (al. (b).

systems that are needed to:

(1) A brief abstract describing tha and (c). SCLn 60.46,50 44. San and 50.30(a)

(A) Shut down the reactor and me or occurrences during the event, "8 * * *E "'"I "

e ded (4 U 2 () Il 6o.1 b and condition:

failures thSt contnbuted to the event (c) and 60 64 are inued under sec.1611. 6s (B) Remove residualheat and significant corrective action taken Stat. 949 as amended (42 USC 2201(1)); and il 50.55(el, Ese(bl. Sofa soft,8052. and (C) Control the release of radioactive or planned to prevent recurrence.

5030 are tuued under eec. telo, os Stat. eso, material: or (2)(l) A clear, specific. narrative ce amended (42 U.54 220stol).

(D) Mitigate the consequences of an description of what occurred so that accident.

knowledgeable readers conversant with A new I 50J3 is added to read as (vi) Eventa covered in paragraph the design of commercial nuclear power (a)(2)(v) of this section may loclude one plants, but not familiar with the details I 60J3 Uooneee event report system, or more procedural errors, equipment of a particular plant, can understand the f ailures, and/or discovery of design, complete event.

(a) Reporroble events. (1) ne hoider analysis, fabrication, construction, and/

(11) The narrative description must include the following specific in[rocedural inadequa cies. llowever, a$t Ifee bmi a r

udt?al component failures need not information as appropriate for the ower o

IJcensee Event Report (1.ER) for any be sepated pursuant to this paragraph if particular event:

event of the type described in this redundant equipmentin the same (A) Plant operating conditions before p ragraph within 30 days after the system was operable and available to the event.

dlocovery of the event.Unless otherwise perform the required safety function.

(D) Status of structures,com onents, or systems that were inoperebbe at tha-e fled in this section. the licensee (vil) Any event where a single cause e all report an event regardless of the or condition caused at least one start of the event and that contributed to independent train or channel to become the event.

ese ofth c noe of the in perable in multiple systema or two (C) Dates and apprnsimate times of structure, system, or component that Ind' Pendent tralna or channals to occurrences.

Initisted the went.

become inoperable in a single system (D)ne cause of each component or (2)ne licensee shallreport:

designed'to:

system failure or personnel error, ti (t)(A)ne completion of any nuclear (A) Shut down the reactor and known.

plant shutdown required by the plant's maidtain itin a safe shutdown (E) De failure mode, mechanism, and Technical Specifications; or condition:

effect of eoch failed component.if (B) Any operation or mndition (D1 Remove residualbest:

k' :wn.

prohibited by the plant's Technical (C) Control the release of radioactive (F) The Energy Industry Identification ppecifications: or material: or System component function identifier

Federal Reg'ister / Vtl. 48. N.144 / Tu:sd:y July 26, 1983 / Ru!

end Regulations 33859 and system name of each component or components that could have performed PART 20-STANDARDS FOR systera referred to in the LER.

the same function as the components PROTICTIOf4 AGAINST RADIATION (J/ ne Energy industry identification and systems that falled during the event.

System is defmed in:IEEE Std 8031983 (4) A description of any c rrective

3. In i 20.402, paragrsph (a)is reused; (May 16.1983) Recommended Practices the introductory test of paragraph (b)is for Unique identification Plants and actions planned as a result i the ever$

revised; and a new paragraph (elis R; lated Facalides-Principles and including thou 6 nduce the pmbabihty added to read as follows:

I'l* d ' " "I' "'*""i"8 I" N D;f

(/ btd 603-1983 has been (S) Reference to any previous similar 120A02 mpons cf thett or low of approved for incorporation b reference events at the same plant that are known

"'***d**'"'*-

by the Director of the FedersfRegister, to the licensee.

(a)(1) Each licensee shall report to the A nouco of any changes made to the (6)%e name and telephone number of Commission. by telephone,immediately cisterial incorporated by referer ce wul a person within the licensee's after it determines that a loss or theft of to published in the Federal Register.

organization who is knowledgee$ ale licensed matertal hee occurred in such Coples may be obtained from the about the event and can provide

{uanuties and under such circumstances Institute of Electrical and Dectrordcs additional informstion concerning the at it sPpean m the hcenne that a Engineers. 345 East 47th Street. New event and the plant's characterisucs.

substantial harard may result to persons Yctk. NY 100t7. A copy is available fot (c) Supplementalinfonnodon. %e Inspection and copying for a fee at the Ccmmission's Public Document Room.

Commission may require the Ucensee to 171711 Street. NW Washington, D.C.

edbmit specific additional bdormation (1)IJcensees having an installed Emergency Notification System shall cnd at the Office of the Federal Register, beyond that required by paragraph (b) make the reports to the NRC Operations 1100 t, St. NW Washington, D.C.

of this section if the Commission finds Center in accordance with ($0.72 of this (C) For fauures of components with that supplemental materialis necusary

chapter, multiple functions laclude a list of for complete understanding of an (11) All other heensees shall make systems or secondary functions that unusually complex or significant event.

rep,rts to the Administrator of the were also affected.

Dese requests for supplemental appropriate NRC Reponal Office listed (ii) For failure that rendend a train of information will be made in writing and in Appendix D of this part.

a safety system inoperable, an estimate the licensee shall submit the requested (b) Each licensee who makes a report of the elapsed time from the discovery information as a supplement to the under paragraph (a) of this section shall, of the fauure until the train was retumed initial LER.

withing 30 days after learning of the loss 12 service.

(d) Submission ofreports. lleensee or theft, make a report in writing to the (1) The method of discovery of each Ennt Reports must be prepared on U.S. Nuclear Regulatory Commission.

component or system fauure or Form NRC 366 and submitted within 30 Docurrent Control Desk. Washington, procedural error, days of discovery of a reportable event D.C. 20555, with a copy to the (J)/l Operator actions that affected the cou)rse of the event including or situation to the U.S. Nuclear appropriate NRC Regional Office usted cperator errors procedural deficiencies.

Regulatory Commission. Document in Apriendix D of this part.%e report cr both, that contributed to the event.

Control Desk. We shington. D.C. 20555.

shall include the following information:

(21 For each reonnel error; the ne licensee shall also submit an addluonal copy to the appropriate NRC (e) For holders of an operating license licensu shall acuss:

(i) Whder the error was a cognitive Regional Office listed in Appendix A to for a nuclear power plant, the events crror (e t. fdive to recognize the actual part 73 of this chapter.

included in paragraph (b) of this section plant coadith !s!1ure to realtre which (e) Report legibility. The reports and must be reported in scardance with the systems shculd be functioning, f ailure to copies that licensees are required to procedces descnbed in 150.73 (b). (c).

d p

must recognize the true nature of the event) or submit to the Commission under the

'}A '6e a procedural error; provisions of this section must be of d

o q

rePorte[h(b)of this section. Events (ii) Whether the error was contrary to sufficient quality to permit legible paragu to accordance with 150.73 of an approved procedure, was a direct reproduction and micrographic result of an errorin an opproved pmcening this chapter need not be reported by a procedure, or was associated with an (f) Exempflons. Upon written request don.

cctivity or task the was not covered by from a licensee including adequate

4. In i 20 403. the introductory text of (fi y unuIalcharecteristics of the justification or at the initiation of the paragraphs (a) and (b) is revised, and work location (e g heat, ee) th,,

NRC staff the NRC Executive Director paragraph (d)is revised to read as directly contnbuted to the erwr: and f r Operations may, by a letter to the follows:

(Ir)The type of personnelinvolved licenue, grant exemptions to the (i.e contractor personnel, utility.

Mporting requirements under this, t 20.403 Notmcetnone of incWente, licensed operstor, utillty nonlicensed section.

(a)Immediate notification. Esch operator, other utility personnel).

(g) Reporroble occurrences. The licensee shallimmediately report any (K) Automatically and manually requirements contained in this section events involving byproduct, source, or initiated safety system responses.

replace all existing requirements for specist nuclear material possessed by (L) The manufacturer and model licensees to report " Reportable the licensee that may have caused or number (or other identification) of each Occurrences" as defined in individual threatens to cause:

component ths' failed during the event.

plant Technical Specifications.

(3) An assessment of the safety ne following additional amendments (b) Twnty-four hour notification.

e nsequences andimplications of the are also made to parts 20 and 50 of the Each licensee shall within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of cvent.This assessment must include the availability of other systems or regulations in this chapter, discovery of the event, report any event

)

involving licensed material possessed

l 33800 Federal Register / Vol. 48, N2,144 / Tuesd y. july 20, 1983 / Rul:s end R:gul:th:na by the licensee that may have caused or (iv) Corrective steps taken or planned (i) Ucensees that have an installed threatens to cause:

to prevent a recurtence.

Emergency Notification System shall make the initial notificadon to the NRC (d) Reports made by licensees in (c)(1)In addition to any notification Operations Center in accordance with response to the requirements of this required by i 20.403 of this part, each (50.72 of this part.

section must be tuade as follows:

licensee shall make a report in wnting of (ii) All other licensees shall make the (1) Licensees that have an installed levels of radiation or releases of trutial notification by telephone to the Erner1;ency Notification System shall radioactive materialin excess of limits Administrator of the appropriate NRC make the reporte required by paragraphs spe'cified by 40 CFR part 190.

Regional Office listed in Appendix D, tal end (b) of this section to the NRC

" Environmental Radiation Protection Part 20. of this chapter.

Operations Center in accordance with Standards for Nuclear Power (7) Wrrtien reports. lloiders of an i 5012 of this chapter, Operations " or in excess of license operating license for a nuclear power-

~

(2) All other licensees shall make the conditions related to compliance with 40 plant shall submit a written report to the reports required by paragraphs (a) and CFR Part 190.

Commission concerning the incidents (b) of this section by telephone and by (2) Each report submitted under included in paregraphs (c) (1) and (2) of tehgram, mailgram, or facalmile to the paragraph (c)(1) of this section must this section in accordance with the desenbe:

procedures desenbed in I $053 (b),(c),

Adrainistrator of the appropriate NRC Regional Office listed in Appendix D of (i)ne extent of exposure of (d). (e), and (g) of this part. Incidents Individuals to radiation or to radioactive reported in accordance with 15053 of this part.

material; this part need not also be reported under

5. In l 20.405, paragraphs (a) and (c)

(ll) Levels of redistion and paregraphs (c)(1) or (2) of this section.

cr3 revised, and new para sphs (d) and concentradona of radioactive material Dated at Washington, D.C. this 20th day of (2) are added to read as lo ws:

involved; July 1983.

I to.a05 Reports of overeuposures and (111)he cause of the exposure, levels

For the Nuclear Regulatory Commission.

cacvaatvo levels and concentrauono.

or concentrations; and g

g gg (a)(1)In addiUon to any notification (iv) Conective steps taken or planned g

g

,o assure against a recuntace, including required by i 20.403 of this part, each licensee shall make a report in writing the schedule for achieving conformance I" b" "*"" S'" '" "I

- - '008 "'**

with 40 CFR Part 190 and with concerning any one of the following associated license ennditions.

types of incidents within 30 days of its (d) For holders of an opereting license occurrence:-

(i) Each exposure of an individual to f r a nuclear power plant, the incidents radiation in excess of the applicable included in paragraphs (a) or (c) of this lir.tita in il 20.101 or 20.104(a) of this section must be reported in accordance with the procedures described in part. or the license; paragrapha 5053 (b), (c), (d), (e). and (g)

(ii) Each exposure of an individual to of this chapter and must also include the radioactive materialin excess of the Informed n required by paragraphs (a) applicable limits in il 20.103(a)(1).

and (c) of this section. Incidenta 20103(a)(2), or 20.104(b) of this part, or rep ried in accordance with 15073 of in the hcense:

this chapter need not be reported by a (iii) Levels of radiation or duplicate report under paragraphs (a) or concentrations of radioactive materialIn

("I

"

U "'

a restncted area in excess of any other I'I applicable limit in the licerse-reports under paragraphs (a) or (c) of (iv) Any incident for which this section shall, within 30 days after notification is required by i 20.403 of leerr.ing of the overexposure or this part; or excessive level or concentration. make a (v) Levels of radiation or report L. writing to the U.S. Nuclear concentrations of radioactivt material Regulatory Commission, Document (whether or not involving excessive Control Desk, Wa shington. D.C. 20555, exposure of any individual)in an with a copy to the appropriate NRC unrestricted area in excess of ten times Regional Office listed in Appendix D of any applicable limit set forth in this part this part.

or in the license.

(2) Each report required under PART 50-DOMESTIC LICENSING OF paregraph (a)(1) of this section must PRODUCTION AND UTILIZATION disenbe the extent of exposure of FACILITIES individuals to radiation or to radioactive

6. In I $0.36, new paragraphs (c)(6) material, including:

and (7) are added to read as follows:

(i) Estimates of each individual's exposure as required by paragraph (b) 1 50.36 Tectmical specenceuono.

of this section:

(ll)lAvels of radiation and (c} * *

c;ncentrations of radioactive material (6)Initio/ Notification. Reports made involved; to the Commission by licensees in (iii)He cause of the exposure. levels response to the requirements of this or concentrations: and section must be made as follows:

l l

l APPENDIX F 1992 REVISION TO 10 CFR 60.72 AND 50.73 INCLUDING STATEMENT OF CONSIDERATIONS Published in the Fodoral Rogister on September 9,1902 September 10,1992 (Vol. 57, No.176, pages 41378-41381)

This Fodora/ Rogister notice does not provide a complete version of 10 CFR NOTE:

50.72 and 50.73; it addresses only small parts of those sections. Its purpose here is to present the Statement of Considerations, which explains some of the reporting requirements of the sections.

NUREG-1022, Rev. i t

~

-~ -__

uws redeveLkneister / voLarrie, t7e / nursday, semanberrto, tso / Rulestated Rasulations

==

certified to OMR. la a letter dated For the Nuclear Regulatory Comminion.

50.72 and to CFR 5073.- Clarificeuon of

^

August 14.1992. that by unanimous vote Samuel I. Odik.

NRC Systems and Guidelines For the Commise6on had overndden the s,cr,saryof sA,corruniwien Reportms." Following resolution of OMB's dmapproval of the information

[FR Doc. 93-21n4 Filed 6.e-42; a:45 ami public comments, the NUREC will be -

cellecuon request associated with this issued in the final form.He NUREG coas m.e,

rule, will contain improved guidance for On August 21.1992. OMB assigned the event seporting.

followmg new control number: 31W 10 CFR Part 50 NRCs reviews of operating 0171. effective until f.ugust 31.1995.

eXPenence and the patterns of licensees

M 3 % AEtt Dis new control number is only reporting of operstang events since 1984 epplicable to the secuons in to CR part Minor ModtScottone to Nuclear Power have indacated that reports on some of 35 cmended by this rule. Information Reactor Event Reporting these events are not necessary for the col! action authonty for all other sections Requirements NRC to perform its safety mission and d

of to CFR part 35 remains under the that contmued reporting of these events axisting general control number: 31W am Nucim Regulatory would not contribute useful information Comsnission.

0010.

to the opereting reactor events c Final rule.

detabase. Additionally.these Ust of Subjects in 10 CFR Part 35 unneces**ry reports would have sussatasm % Nuclear Regulatory conunnd to ccasume boe the Eyproduct meterial. Criminal penalty-Conuaission (NRC) has amended its licensees

and the NRCs resources that Drugs, Health facilities. Health regulations to make minor modifications prolewions, incorporation by refence, to the current nuclear power reactor could be batter applied elsewhere. The Medical devices. Nuclear r.neterids, event reporting requirements, ne final NRC has determined that certain types Occupational safety and health, rule applies to all ruclear power reactor of events, primardy,those involving Radiation protection. Repor*ing and licensees and deletes nporting invalid enginured safety fea1ure (ESF) recordkaeping requirements, requirements for some events that have actuations, are of little or no safety Text of Final Regulations been determined to be oflittle or no sigmficance.

safety significance.ne Anal rule Valid ESF actueuons are inose For the reasons set out in the reduces the industry's to

'ng burden actuations that teouk from "veihd pre:mble and under the authonty of the and the NRC's response en in event signals" or from inteadonalmanual Atomic Energy Act of1954, as amended. Ieview and mewawat.

initiation. unless it is partof PMP anned test. Valid signals are those l

the Eneegy Reorgaalzation Act of 1974.

anscTwa nave October 13, tr92.

ee ameeded, and 5 U.SE.,552 and 553, signals that are laitiated Ipeepoone to m Mm wonnanosa com the NRC is adopting the following actual plant condition' eyesumeters s

smendments to to CFR part 35.

yis an the requirements forESE g

PART 35--MEDIC 41.USE Op Nuclear Regulatory. Commission, WYPRODUCTABATERIAL W shington.DC30Calephone(301) g*g%,8 H

d amt Mu"*"'sta*';*'"*"~~*

cott*"*:W"*"'20

- " - ^ =

so

,t s

Ba W of valid signals and are not latenticaal Ausher6ey: Sam.101, es Stat. 044 es manual actuations. Invalid actuations sanended its UAC taos t sec. an. es Stat.

% r%==1== ion is issuing a final rule include instances where instrument 1242. se amended 142 UAC. 544tl * * *.

that amends the nuclear power reactor drift, spurious signals, bemas erfor, or

2. In i 35A paragraph (b)is revised nut mpadag requirements contaaned other invalid signals caused actuation of in to CFR 5&72. "t===diate Notification und paragraph (d)is vided to read as se ESF(4 W a csWnet, an wror follows:

Requiremente for Operating Nuclear in un d Mpme d HAadluds, an wror Power Ructors " and 16 5473, in actuation of switches oc controls, 9354 eneermemen sessenen "Ucensee Bvent Report System." ne equipawat fdure, w mdio frequacy agueremones: cess espeevet.

final rule is leaued as part of the interference).

Commierton's ongoing activities t NRCs evaluation of both the reported u roments contahwd la this 1

t a fire ecti e,and p rt appear in il 35.12i35.13,35.14.

and 10 CFR 50.73 (a)(2)(lv). Or lune 28' the comments remtved during the Event 35.21. 35.22.35.23,35.27.35.29. 35.31.

1992 (57 FR 2e642), the Commission

- 35.50. 35.5L 35.53,35 50,35.00. 35A1.

issued a proposed rule mquesung puW Reporting Workshope conducted in Fall of 900identifiedneededImpenvements 31.70. 35.e4 35.32. SW 35.205, 35.310, comments se these====d===ta.

in the ruin *The NRC ddterudaea that~

35.*ts.15A04. 35.C08,35.410J 35.415 Over the past several years, the NRC 35 806,35.810,35215,35.630,35A32, has increaaed its attention to event d Wh Wh w ESPs

.35.836,35A4L 35.643,35.645. and "

neluding the systems, subsystems, or la Sep(ember 1991, the NRC's components (i.e., an invalid actuation,

-e e

e forAnalysis and Evaluation of isolation or realignment of only the (d) OMB has assigned control number OpwouonalData (AEOD)inued for reactor weter clean-up(RWCU) system.

3150 0171 for the infonnation collectica comment a draft NUREG-1022. Revision requimments contained in Il 35.32 had g,i" Event Reporting Systems to CFR Naciser Rapdatory rw Wesbesense.DC

't5.33.

sensa A ener is else evenable est tusseensa er eme.yies ime e fee at the fetC Pubhc Doesammt Deled at stockvdle. Marytend, tma ad ciay i p,..ings, e.,y eney t,e,ogenesed by vmmas te a.

m t,sereen, pne.go r tov ek.

OI D ' I N the Deserttemen and Matt Servteen Section. U.S.

WeeheestasL DC mesa I

rederal Registers /*Nolh62nNo 4L76:/4httrsdaytdieptainbordage@@My@t4:Wm the controi room emergency ventilation ventilation system, auxiliary building This ndeexdades4.ree categmes of (CREV) svstem, the reactor building ventilstion system, orth'.fr equivalent events frors reporting, venulation system, the fuel building ventilation systems),ne' actuation of (1).ne first category excludes events veriutation system, or tne auxiliary the standby gas treatment system m which an invalid ESFor RPS building ventilation system. or their foUowing an invalid actuation of the actuation occurs when the system is equivalent ventihtion systems) are of reactor building ventilation system is already properly removed from service little or no Safety sigruficance. Ilowever. also exempted from reporting. in if all requirements of plant procedures these events are currently reportable '

addition, the final rule excludesTrivalid for removing equipinent from seryce under 10 CR M72 (b)(2)(ii) and 10 CFR sctuations of these ESFs (or their_

have been met.His includes required 50.73 's)(2)(lv).

equivalent systems) trom signals that clearance documentation, equipment i

The final rules for the current event onginated from non-ESF circu try.

and control board tagging, and properly reporting regulations 10 CFR 50.72 and liowever, invalid actuations of other positioned valves and power supply to CR 50.73 (48 FR 20039; August 2r.

ESFs would continue to be reportable.

breaken i

1983, and 48 G 33:50; luly 26.1083, (2) De second category exdudee l

res tively), stated that ESF systems.

*"* E,*

events in which an invalid ESFor.RPS g Uom dua inc uding the reactor protectiois system actuation occurs after the safety (RPS). are provided to mitigate the

{"f*g{" *(g*

Y*[iQ'w, function has alreadybeen completed-consequences of a significant event.

(e.g an invalid containmentisolation.

Herefore. ESFs should (1) work flow, essentiaj sup.oort P.

4 etc g

g g

properly when called upon and (2) containment spny aduw nM should not be challenged frequently or residual best removal a stem isolations valves are already clo' ed, or an invalid s

g unnccessarily, ne Statements of (or syste ne designated any other g

Consideration for these final rules also names but designed to f the

.g stated that operation of an ESF as part function similar to these systems and b

d ESF mh of a pre-planned operational procedure their equivalents), are still reportable. If or test need not be reported.ne an invalid ESF actunuon revesls a g

g g

ggg Commission noted that ESP actuanons, defect in the system so that the system g

g g

including reactor trips are frequently failed or would fall to performi's associated with signdicant plant it. tended function, the event continues to RWCU 's'ysieni.4r any of the foUowing g

gg transients and are indicative of events be reportable under other requirements that areof safety eigmficance. At that of to CR 50.y2 and10 CFR 50?3.lf a reador banding ventilatidn' system, fuel g

gg g,g buu @ e Wa h s # g,,,g time, the Commission also required all condition or deficiency hss (1) an gg,

- Nr ESF actueuons, including the RPS advene impact on safety related 4

actuations, whethermanualer equipment and consequently on the automatic, vahd or invalid-except as ability to shut down the reactor and ad MWG Wh noted, to be reported to the NRC by-maintain it in a safe shutdown ESF8 8'ot'specificall ~W f*^

I telephone within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of omurrence condition. (2) has a potentialfor b

[cu

'='4 followed by a written 1Acensee Event significant radiological ~ release or, g g, g g g g,g,g,"cg Report (1.ER) within 30 days of the potential exposure to)lant personnel or incident. His requirement on timeliness the general public, or (3) would cooling systemsimalaistaenill.,ow' of reporting remains unchanged compromise control room habitabalty, essuua} suppod systems.3%

ne repor*.ed information is used by the evetit/ discovery continues to be catainmed spny aduaWed a(

the NRC in cor.firmation of the licersing reportabla.

- - "****I'"

bases, identification of precursors to Invalid ESF actuations that ara c dehcienca excluded by this final rule, bu,t occur as Ycens)s continue to be required to I

p ant s lessons, review of management control 8 part of a reportable event, continue to submit LERs if a deficiency or condition be described as part of i e npodable associated with any of the invalid ESF systems, and licensee performance assessment, yvent.nese amendme:A 3re not actuations of the RWCU or the CREV mtended to preclude submittal of a systems (or other equivalent ventilation Discussion complete, accurate, and thorough systems) satisfies any reportability ne NRC hee determined that some description of an event that is otherwise criterin under i 50.72 and i NJ3.

events that involve only invalid ESF reportable under to CR 50.72 or to CFR i

actustions are of little or no safety 50.73.ne Commission relaxed only the Impact of the Aad===*a se the j

significance.Ilowever not allinvalid selected event reporting requirements It'dustry and Government Rasources ESF actuations are being exempted from specified in this final rule.

Relaxing the requirement for reporting reporting through this rule.ne

!.icensees are still required under 1C of certain types of ESF actuations relaxations in event reporting CFR part 50, appendix B. Quahty reduces the industry's reporting burden requit ments containad in the fim! rule Assurance Criteria for Nuclear Power and the NRC's response burden.His apply only to a narrow, limited n. of plants and Fuel Reprocessing Plants," to reduction is consistent with the specificady defined invalid ESF address corrective actions for events or objectives and the requirements of the actuations. nese events include invalid conditions that are advarse to quality Paperwork Reduction Act.%ese actistion. isolation, or realignment of a whether the event is repertable or not.

amendments have no impact on the Jimit,ed set of ESFs ine1"% systems in addition, minimizing ESF actua tions NRC's ability to fulfill lis mission to subsystems, or components (i.e., an (such as RWCU isolations)to reduce ensure public health and safety because invmhd actuation. Isolation, or operational radiation exposures the deleted teportabilIty requirements realignment of only the RWCU systes associated with the investigation and

iave httle n no safety: P%

or the CREV system. reactor buildina recovery from the sietuations, are It is estimated that the changes to.the ventilation eyatem fuelbuilding consistent with A1. ARA requirements.

existing rules wiD result Isabout.150 (or

l l

gy&

WP^f ?'k 2

3, MOpercent)fewertfoonsee%vue(

thelrecitterno dboet bliminettag the average 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months per licensee response.

Rzports each year. SiseDartoductions selected event reporting % L a.ts.

Includmg the time required reviewing are expected tnibe snmaberofprompt Deee comunenters believe that the instructions, w"5 amisting dela sysnt notinceuen.s wpoi9eble under10 elimination of these event reporting sources, gathering and maintaining the CTR 50.72. Sonne ~, _ ' J.-,intheir requirementsiney adversely affect the dela needed,andreviewing the con.ments on the i,4 :i vule,deted NRC's information databue and collection ofinforsnation. Send June as.1992 embadtted en estimate of ultimately e5ect the esency's ability to comments regarding the asumated approximately 15 percent redoction in carry out its mission to protect public burden reducnos or any other aspect of their reporting burden.

beelth and safety. For many years, the this collection of information. including S"""*'IdP e NRC etaff has been systematacally suggestions for reducing this burde i. to reviewing information obtained from the information and Records W NRC recatsed 13 ocaunente-4 IJconsee Event Reporta.Deee Management Branch (MNBB-7714). U.S.

fr;m individuals, a from industry-amesments of reactor operational Nuclear Regulatory Cr===laalaa supportedorgn=a==a'a== and14 from exponemos have todeded data on the Waeldagton. DCsones;and to the Desk utilities.Esmeptdermere -

'ts,all types of events lasteded ta the three 05toer.OfSee ofinfermenes and commenters weisemmedthe categones thaf the NRC is deleting from Regulatory A5eirs.NEOS aste.(315c-Commasalan's e5erts assedsos the reporttag.De staff's reviews and 0011 and 315&ct06).OIRoe af licensee burden and tosave she essessments of aearly1000 roedor" Management and Budget. Washington.

agency's reseamos ta event soview and years of operational exponerace have DC 30503.

proceaems.De stdiales and the identified r ^'";no safety indestry.eupparesdaay==A =*'a==

signine==a= assedated setth the type of Regulatory Analysis expressed their desire for a broader events lacladed da the afor=====Ha=ad relamanento$mdadealliavalidESP three catagorisa. De a==aaaaaa has De Commisdonha propued a

_ _ m. -.,,p,, gg, g,,g g actuationsfromsuportas.

reviewed ahe afthese Other aa====as dien she n r

amendments.

enthe basis of the N analysis b e nd beents de altansene maddM cencerned the louewing: miadfdation of sta5's assessment r4 the past seactor thi deAaltleamillosalad"ma*==Ha=

operational awpah has by1he Couenaselon.%e analysisle examples of esesesbeing esempted

=+

-M= eaael= dad evith a ayellab'io for toepecean in she NRC from reporting:seasidesationalsdaat-reasonable Aaand==e, that islamatica Public Document Room.'t130 LStreet.

specific situatiemmemmaptiondrom from reportlagof events in the three NW.Lowe lavel. Washington DC teportingof theasesatiosef thestandby categorias does not a5ect the ageoefs 20555. Single copies of the analysis may 3:e treatmast systema (elloonasan ability to neotectpublichaahkand be obtained froneRa pathl. Man invalid actuanism af abe seactorbuilding safety, for Analysis and E tion of v:ntilation andpossibly Based on the inpet from the utBities.

Operational Data,modear af Amenlid,

them amendments wS1 reduce the Regu1storyen==la=Aa= Washlagton, extending /lestadensofRWCU from cetuations industry's reporting burden byabout 15 DC L655. Telephone (301) m to to Iael-da samaof the percent.no estimated savings of the a o

---g m ch and solumesacatrolsystem An NRC's response burden la event review a presourtsed mataranacter.N and eesessment is about 6-10 percent.

la accordance with $3 Regulatory Statement of Cassiderstlans fer tids Flexibility Act of 1980 (51,I.EE. 405 (B)).

finalrule addresses most af these EnMImpedaW the Co==laalan certines that this. rule conc =ma. Otheriseoas and elaane= Haaa Excluelse does not have e alg='Aca=8 eaaaa=ic conceralas eventieportabRity will be ne NRC has t'atermined that this impact on a substandal asseber of sanall addressed in NUREG "o22. Revision 1.

Gaalrulees thet of sodon described entittu.& Real rde a5ects only the Hrwever. It is not practicalJo add =as a in categortaal==

la== to CFR 41.22 event reportag requirements for plant < specific =in=aesa= unless it relates (c)(3)(li) and (iii). Derofere, neither sa opereunaal seclear peerer plants. De is a gener6c comsmen.

envirosamentelleapect statement not an companies that owm ahene plaats do not h Comadselen stresses that only environmental=========e has been fan within the scope of the deAnition of certain sped $clevelidESFactustions prepared for this final rule.

"small entitles" set forth in the am beW eumpted front reporting through the present===ad-ta.

Paperwosk Waduettaa Act Stateameg Regulatory Flexibility Act or the Small Business Size Standards set outin NUREG-Is22.Reviolon1 will contata Tide final rule====da laformation specific =va-pl= and additional collection requirements that are subject regulations leeued by the Small Businese guidanon on events widda are posendy to the Peperwork Reduction Act of 1900 Administretion Act in 13 CFR part 121.

reportable no well as those which are (44 U.S.C. 3501 et seq.). nase Baci6 fit Analysis bems exempted from reporting through a=aad===t= were appenved by the these amendments. lathe future, the Office of u.--

- t and Budget As required by to CFR 50.109, the ca==8-aan win give due considenstion approvalmusibere 3150 0011 and 3150-

^==lataa has - -,._ _ an sesessment of the need for Backfit to other pioposed r=lawartana frons 0104.

evsnt sporting after the NRC staff has Because the rule willrelax existing Analyste for this fins 1 rvle.%e hrd an opportunity to reassess the data mporting requirements, public reporting proposed amends minclude needsof theassexyandperfoaned burden of intennation is expected to be relaxations of c.- Ah extenas s:fety assessments tolustify hdtiation a reduced. It is estimated that about 150 requimments ca repareas of inlansetion separete sensent =ta-afring Untitu_h fewer 12-Event Reports (NRC to the NRC.%ese changee melther time, all events motspedHeally Form see) and a similarly reduced impose additionalreporting exempted in theos==aad=aata contian number ofpros.pt event notiGcations, requireannis nor regehe =aane=tions to be reponable.

made pursuant to to CFR 50.72, wiD be to the fadlities or theirlicenses.

Detwo.

" J,.who opposed required each year.%e eveulting Accordingly,the.NRChasconcluded the i,+.J emendments expmesed reduction la burdenis estimated to that this final rule does not constitute a

Fedesel Regislar./ hsy. Ns.17st/ %aredeA eptember1tL*19er / Riales andJtesalatimes. 4:331 8

backfit end, thus, a beckfit'enelysie le

2. In 5 50.y2 paragraph (b)(2)(ll)le For the Nuclear Reguktery t'm not required.

revised to read as follows:

James K Tayler.

cud or Owmdom.

Det of Subjecie in 10 CFR rart se Iso.72 lemmastenonnaeuen Antitrust. Clasoified informa tion.

- ' ' N "***'*'P " *'

Criminal penalty. Fire prevention, incorporation by reference.

Intergovernmental relations. Nuclear (b) Non-emergency Events. * *

FEDERAL RESERVE SYSTEM power plante and reactore Radiation (2) Four. hour reporte.

ptotect on. Reactor siting criteria.

(ii) Any event or condition the,t results 12 CFR Part 225 Reportmg and recordkeeping.

In a manual or automatic actuation of for the usons set out in the any engineered safety feature (ESF).

(Reguiston V8 Docket No.R-470s) preamble and under the authority of the including the reactor protection system RW 7%ASol Atomic Energy Act of 1964. as amendsd. (RPS). except when:

the Energy Reorsammation Act of 1974.

(A) b actuation resulte from and is Bmk Holdhg 6 med Clienge se amended, and & UAC. 552 and 553, part of a pre-planned sequence during h Bak Cwrol the Coaumesion is adopting the testing or remeter operation:

followmg amendmente to 10 CFR part (B) b actuation is invalid and:

acancy: Board of Governare of the 50.

(1) Occure while the system is Federal Reserve System.

prortriy removed from service:

Actioet Final rule.

PART 50-DOMESTIC UCENSING OF (2) Occure after the safety function PRODUCTION ANOUTlu2ATION has been already completed:or euesesAmy:'!he Board le amending its FActuTIES (3)Invoine only the following specific Regulation Y to augment the tiet of 1.W auinority citation for Part 60 le ESPs or bir equivalent eyetmas:

praissele nonW m b reviend to read as follows:

(/) Reactor water clean-up eyetem:

bank holding companlee to insiede the (li) Control room emergency Provision of hill service sacerttles Authew Sece, iat.102. 2% tos, set. is2.

ventilation system:

brokerage under certain oceditions; and

[eIe sec.234.Is (iii) Reactor building ventilation the provleion of financialadvisory e

1244. as amended 14 uAt staa. 2:33, atu.

system:

services under certais conditions. N 2 35,2201.2232.22 3,atmtaos,asaak esce.

(iv) Puel building ventilation eyetem:

Board has by orderpenteuely appsowd am.= eme ded. sat.an as sist.ua, u or theu activitia. Applicetions by bank eawndmL 1244.124e H2 USC seet.m2 (v) Auxiliary building ventilation holding companies to engagein saeet systent.

activttles included on the RegulatiomY secuen ur eine leased under pub. L es.

gi,iog,,

-, h w.g este,ities sot.sec.m et mt. set la UAc sost),

me be processed by th.e. Reserve senke d

- _. g secuem sate also inesed ender esca. toi, ses

3. In I so.ys, paragraph (e)(2)(lv) la a sset.em as.n emended na uAc tist revised to read aa fonows:

'" - - - - + - -

1 enthority.

223sk eec. set. Pub. L et-ion es siet. as:Hz UAc eaan.seenene casa,uselddk ena i ca.ys unansee esent esport eyeseni, appscTive oAne September.te,1 set, antos eine immed ender sec.tos, es siet. eso.

(aJ Reportable events. * *

poa pusmeen esposesAMOs000ssTACT.

m emended Ha uAt us).seouses so.as.

(2) b Bommee shall report' * *

Scott G. Alveres, Associate General

EseYt,Ng'"'*N22:s (iv) Any eventarmondition that Counsel (202/45245as),or'Ibomas M.

sa33a. sasse. and Appendia Q else immed resulted in a manual or automatic Corel. Senior Attorney (302/45s4275),

under uc. tat. Pub. L n-m, as si.e. es:9: ectuation of any enginemed saf*ty Legal Diviolon. For the heasies impaired UAc esazt secnees ease and es.s4 also feature (ESF), includlag.the reacter only.Telecomunanications Device for inwd under uc. ao4. en siet. taas na uAC protection system (RpS), except when:

tlw Deaf (U)D).Dorothea Thompon sa44k Sectems so.sa, saet. and saea eleo (A)W ectuation resulted from and (202/463 4 644).

uY 2N:m N Esi7io j'os[*

[*j,,

, g part o a supMmmetrAny esposesAWest me.

siet.

u a c 21

.p.

(B)h actuation was invalid and:

Background

n r,,

e64.u amended 9 UAc 2:34k Appendix F (1) Occurred while the system was W Bank Holding Company Act of eleo loomed under sec. ter, es siet. ess 62 properly removed from service:

1956 as amended (the "BHC Act").

u A c 2237).

( Occurred after the safety function generally bits a beak balding For the purposee of sec. nas, as ht. eso, se had already -m' ;.,1, or company engaging in - ~ ' ' h=

emended H2 UAC 2273k ll sea sate (s)

(3)In;rolved only the foHowing activities or acquiring votleg escurities Un*,L dM *,",,','",",,d=ag specific ESFe or their eqmvalent of any company 1het is not a beak.

e g,

tam (b)k i e sas, sa.rp), sateWHel so.34(a) systems:

Section 4(c)(e) of the BHC Act provides and lok sa44(eHel, saaek) and (b), sa47(b),

(1) Reactor womt eles: cup eyetem; an exception to this prohibitide where meekk ick Idt and (ok steelek sautek (i),

til) Control momergency the Board deterinirwe after notler and-(Iht1 (1 Hat (pl. tok (t), tok and tyt sass (0, ventilation systees:

opportunity for bearing that the sassele),(chek (a), and(hk nasetet (Ili) Reactor building ventilation activities being condoctedare "so samlet saea(bk saae@L se*A and seso(el system:

ckisely related to henking or managing

- d @I Q'""'d,e Q C 38"I'Ik'"d eer.sett se stat.

(iv) Pnel building ventilation sysien or controlling banks as to be aproper y,, **

I or incident thereto."12 UAC.~ tees (c)(s).

I*

(r) Ausihary buildingventilation b B6erdle aethorised to mains this L

e

(

g strolet aartieHel and lek sos 29), soyag) system.

determinetion by order in an indrvW=1 and (b), satt. sara, and saco are leoned.

case or by regulation, under see, tete,-es siet. sea se emended H2 Desed et Rockville. MD. this 27th day of The Boardo Regulation Y (12 CFR part uAc 22019)).

Auguet. test.

1.25) sete forth a tiet of nonunHng r

kNn-

NRC 7one 336 U s. NUCLEAR REIULATORY COMMiss10N

1. REPORT NUMBER p 89

{ Assigned by NRC, Aad vol., supp., Rev.,

EoY32 BIBLIOGRAPHIC DATA SHEET

* * ^ " * " ' " " " " * * " ' ' " ' " "

rSee espuctuana en Pe reverse) 2 TrTLE AND SUBTITLE NUREG-1022, Rev.1 Ev:nt Reportng Guidehnes 10 CFR 50.72 and 50 73 3

DATE REPORT PUBLISHED j

j Second Draft for Comment uours vEAn January 1998 g

4 FIN OR ORANT NUMBER 5 AUTHOR (S) 6 TYPE OF REPORT D P. Alhson, M R Harper, W.R. Jones, J B. MacKinnon, S S. Sandin Regulatory 7, PERIOD COVERED (sactusve DesesJ l

8. PEUORMING ORGANLZATION - NAME AND ADORESS (rNRC prove orvem once w Regm u s weer Regewy conm um av mang ed*eu #ea*ecw.

mm nome eu meseg esens)

Office for Analysis and Evaluaton of Operatonal Data U S. Nuclear Regulatory Commssion Washington, DC 20555-0001

9. f*PONSORtNO ORGANIZATION NAME AND ADDRESS tvNRC, type 'some es soove*, vcontech. prove NRCDvem oece a Regm u s wena Reguwory canmessen, and meeng edeen )

Same as above.

1o. SUPPLEMENTARY NOTES 11 ABSTRACT (2ao.anss a ws)

Revision 1 to NUREG-1022 clanfies the immediate notfication requirements of Title 10 of the Code of Federal Regulatons, Part 50, Secton 50.72 (10 CFR 50 72), and the 30-day wntten licensee event report (LER) requirements of 10 CFR 50.73 for nuclear 4

power plants This revision was instated to improve the reportng guidelines related to 10 CFR 50 72 and 50.73 and to consohdate these guidehnes into a single reference document. A first draft of thrs document was noticed for pubhc comment in the Federal Register on October 7,1991 (56 FR 50598). A second draft was noticed for comment in the Federal Regrster on February 7, 1994 (59 FR 5614) This document updates and supersedes NUREG-1022 and its Supplements 1 and 2 (pubhshed in SIptember 1983. February 19B4, and September 1985, respectvely)..wes not change the reportng requirements of 10 CFR 50.72 and 50.73.

12. KEY WORDS/DESCRIPTORS (bst uses a phrases enet we assmf resserchers e beeong me repat) 13 AvAILAstuTV srATEMENT unkmited Emergency Nobf!caton System Event Report M JECURITY CLASSIFICATION tmmediate Notficaton Una F=9*>

Ucensee Event Report unclassrfied Notfication (Tms Repart; Report unclassrfied

15. NUMBER OF PAGES 16 PRICE NRC PORM 335 p.8%

i SPEC 1AL STANDARD Mall l

UNITED STATES POSTAGE AND FEES PAID NUCLEAR REGULATORY COMMISSION USNRC WASHINGTON, DC 20555-0001 PERMIT NO. G-67 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300 1

1 1 Anils 11M19Cl 170555154486 US t.RC-01RM TPS-POR-NUREG ZWFN-6E7 OC 20555 WASHINGTON

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ML20199M068

Text

SUMMARY

1.1 Background

1. Background

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