Information Notice 1994-73, Clarification of Criticality Reporting Criteria
i
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C.
20555
October 12, 1994
NRC INFORMATION NOTICE 94-73: CLARIFICATION OF CRITICALITY REPORTING CRITERIA
Addressees
All fuel fabrication facilities.
Purpose
The U.S. Nuclear Regulatory Commission is issuing this information notice to
alert addressees to a clarification of the criticality reporting criteria
previously provided in Bulletin 91-01, Supplement 1. It is expected that
recipients will review the information for applicability to their facilities
and consider actions, as appropriate, to ensure proper reporting.
However, suggestions contained in this information notice are not NRC requirements;
therefore, no specific action nor written response is required.
Background
On October 18, 1991,Bulletin 91-01,
"Reporting Loss of Criticality Safety
Controls," was issued. It requested that addressees inform NRC of their
criteria and procedures that ensure the prompt evaluation and reporting of
conditions and events involving criticality safety. The NRC staff reviewed
each licensee's response to the bulletin. Most responses reflected a
commitment to promptly evaluate events with criticality safety implications, report the most significant events immediately to NRC, and report less
significant events within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Also, we received numerous comments on
the bulletin through correspondence and various meetings and workshops. A
major concern was the bulletin's statement that loss or lack of a controlled
parameter related to criticality safety should be reported to NRC immediately.
Several persons noted that further clarification regarding the definition of
"a loss of a controlled parameter" is needed. Others noted that a loss of a
controlled parameter is not always a significant event warranting an immediate
report (e.g., if the event involves only a small amount of special nuclear
material).
Some licensees maintained that they should report events
immediately, to NRC, only if there were a significant threat of a criticality
accident or if the severity of the threat could not be readily determined.
As a follow-up to Bulletin 91-01, Supplement 1 was issued on July 27, 1993.
The supplement was issued to (1) provide addressees clearer reporting
criteria; (2) request that addressees take certain actions; (3) require that
all addressees report to NRC whether, and to what extent, the requested
actions would be taken; and (4) notify NRC when actions associated with this
bulletin were completed.
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IN 94-73 October 12, 1994 Bulletin 91-01, Supplement 1, was not intended to affect license requirements
nor licensee actions involving accident mitigation, emergency response, nor
long-term corrective measures. Such actions should be performed in accordance
with the license and established regulations.
Description of Circumstances
Subsequent to the issuance of Bulletin 91-01, Supplement 1, NRC received
significant comments. In response to those comments, we are clarifying
Criterion 1 for reporting events immediately.
Discussion
Bulletin 91-01, Supplement 1 was issued to clarify the events NRC wanted
reported immediately.
It limited immediate reporting to those cases where
(1) moderation was used as the primary criticality control, or (2) more than a
safe mass of fissionable material was involved (regardless of the type of
controls used to satisfy the double contingency principle).
In addition, the
cases had to meet one or more of the four immediate reporting criteria that
were listed in the supplement.
For further clarification, definitions were
provided for the four terms used in the immediate reporting criteria.
As noted, NRC received significant comments after the issuance of
Bulletin 91-01, Supplement 1, In response, we are rephrasing Criterion 1 of the Supplement by expressing it as two separate criteria. As a result, there are now five criteria. We are also making it clear that we expect the
reporting individual to be one who is knowledgeable about the plant's
operations, such as an operator or a manager.
The resulting criteria, and the accompanying definitions of terms, are
presented in their entirety below.
Immediate Reporting Criteria
NRC requests that the following situations should be identified and reported
within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the initial observation of the incident by a knowledgeable
individual, such as an operator or a manager. These include situations where
(1) moderation is used as the primary criticality control, or (2) more than a
safe mass of fissionable material is involved (regardless of the type of
controls used to satisfy the double contingency principle).
In addition, the
situation must meet one or more of the five immediate reporting criteria
listed below:
1. When, for a given criticality pathway, the controls, control systems, or
controlled parameters that provide for double contingency cannot be
reestablished within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
2. When, if double contingency has been reestablished within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and
a. only one controlled parameter is used for a given criticality pathway, and more than one control system has been replaced or modified; or,
IN 94-73 October 12, 1994 b. more than one controlled parameter is used for a given criticality
pathway, and the control systems for more than one controlled
parameter have been replaced or modified.
3. The occurrence of any unanticipated or unanalyzed event for which the
safety significance of the event or corrective actions to re-establish the
double contingency principle are not readily identifiable.
4. Any case where it is determined that a criticality safety analysis was
deficient and where the necessary controlled parameters were not
established or maintained.
5. Any event involving a controlled parameter previously identified by NRC or
the licensee as requiring immediate reporting to NRC, and where the double
contingency principle cannot be re-established within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the
initial observation of the event.
Definitions
Control means a restriction established to limit: (1) the behavior of
individuals to prescribed actions, or (2) the behavior of a variable or
the operation of a component, a process, a portion of a process, or a
system to performance within defined limits, to prevent an accident.
Controlled parameter means a measurable variable whose value is maintained
within established limits, to ensure the safety of an operation.
Control system means a collection of restrictions that effectively
functions as a single control.
Double contingency means, for each criticality pathway, the use of control
systems in such a way that two unlikely, concurrent, independent control
system failures would have to occur before an inadvertent criticality
would be possible.
Events and/or conditions that satisfy the above criteria should be reported
within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from the initial observation, in accordance with 10 CFR 20.2202 and 10 CFR 70.50.
All other criticality safety events that do not meet the aforementioned
criteria, but still result in a violation of the double contingency principle, such as events where the double contingency principle is violated but control
is immediately re-established, should be reported to NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, in
accordance with the commitments in the responses to Bulletin 91-01, and
Bulletin 91-01, Supplement 1.
It is expected that criticality safety events will be promptly evaluated and
that appropriate management and technical personnel will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
a day to perform such evaluations.
IN 94-73 October 12, 1994 It should be emphasized that it is important that NRC be notified of events
related to criticality safety and that if there is any doubt as to whether an
event should be reported, the NRC should be contacted.
Information Notice Treatment
Addressees
may wish to review their 4 ensure that they meet or exceed the i
information notice. If you have any
notice, please contact the technical
regional office.
criticality safety reporting procedures to
reporting criteria described in this
questions about the information in this
contact listed below or the appropriate
Robert F. Burnett, Director
Division of Fuel Cycle Safety
and Safeguards
Office of Nuclear Material Safety
and Safeguards
Technical contact:
Attachments:
1. List of Recentl~
2. List of Recentl1 Jerry
(301)
Roth, NMSS
415-7156
, Issued NMSS Information Notices
( Issued NRC information Notices
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NMSS GENERIC COMMUNICATION ROUTING SLIP
Title:
IN 94-XX
CLARIFICATION OF CRITICALITY REPORTING CRITERIA
Concurrence:
(Please expedite. Mark any editorial or minor technical comments on the
original and send it to the next person on the list. All comments will be
considered before the document is issued. If there are major technical
comments, please call the originator and discuss them.)
lJ
Originator
Originating Section Leader
Originating Branch Chief
NAME
Ill
Lance Lessler
08/18/94 Jerry Roth
08/22/94 Phil Ting
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08/23/94 Concurrence routing (specify offices):
NOTE:
ERR concurrence (Div. Dir. or higher)
required for U~s appticabLe to reactors (IncLudes IUs addressed to aLl NRC licensees).
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Issuing Division Director
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Secretary, NRR/ADP
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Issuing Branch Secretary
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Issuing Division Director
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K. Ramsey
R. Burnett
3 J. Lindsay
P. Harich
R. Burnet
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Issuing Branch Secretary
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P. Harich
15NMSS GENERIC COMMUNICATION ROUTING SLIP
MIS /- Yew.
Title: CLARIFICATION OF BULLETIN 91-01. SUPPLEMENT 1 Concurrence:
(Please expedite. Mark any editorial or minor technical comments on the
original and send it to the next person on the list.
All comments will be
considered before the document is issued. If there are major technical
comments, please call the originator and discuss them.)
Originator
Lance Less
91q
Originating Section Leader
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Originating Branch Chief
Phil Ting
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Concurrence routing (specify offices):
NOTE:
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required for lls appLicabLe to reactors Cincludes INs
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Technical Editor
Director, NMSS/PMSI
(Coordinate BLs & GLs with ACNW/ACRS)
Generic Communications
Coordinator, IMOB
(Verify format, forms, & program codes)
Issuing Division Director
(Concurrence only)
Secretary, NRR/ADP
(Numbers assigned, attachments provided)
Issuing Branch Secretary
(Print final document)
Issuing Division Director
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Issuing Branch Secretary
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89/21/1994
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I"I94-73 October 12, 1994 It should be emphasized that it is important that NRC be notified of events
related to criticality safety and that if there is any doubt as to whether an
event should be reported, the NRC should be contacted.
Information Notice Treatment
Addressees
may wish to review their i
ensure that they meet or exceed the l
information notice. If you have any
notice, please contact the technical
regional office.
criticality safety reporting procedures to
reporting criteria described in this
questions about the information in this
contact listed below or the appropriate
Robert F. Burnett, Director
Division of Fuel Cycle Safety
and Safeguards
Office of Nuclear Material Safety
and Safeguards
Technical contact:
Attachments:
1. List of Recently
2. List of Recently
Jerry Roth, NMSS
(301) 415-7156
Issued NMSS Information Notices
Issued NRC information Notices
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IN 94-XX
September
, 1994 It should be emphasized that it is important that NRC be notified of events
related to criticality safety and that if there is any doubt as to whether an
event should be reported, the NRC should be contacted.
Information Notice Treatment:
Addressees
may wish to review their i
ensure that they meet or exceed the
information notice. If you have any
notice, please contact the technical
regional office.
criticality safety reporting procedures to
reporting criteria described in this
questions about the information in this
contact listed below or the appropriate
Robert F. Burnett, Director
Division of Fuel Cycle Safety
and Safeguards
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
Jerry Roth, NMSS (301) 415-7156 Attachments:
1. List of Recently
2. List of Recently
Issued NMSS Information Notices
Issued NRC information Notices
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IN 94-XX
September
, 1994 n ormation Notice Treatment:
Addr sees may wish to review their criticality safety reporting procedures to
ensure that they meet or exceed the reporting criteria described in this
Informa ion Notice. If you have any questions about the information in this
notice, ease contact the technical contact listed below or the appropriate
regional o fice.
Robert F. Burnett, Director
Division of Fuel Cycle Safety
and Safeguards
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
Jer
Roth, NMSS, (301) 415-7156 Attachments:
1. List of Recently Issued MSS Information Notices
2. List of Recently Issued
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IN 94-XX
August
, 1994 Reouest Actions
It is sug ested that addressees review their criticality safety reporting
procedures to ensure that they meet or exceed the reporting criteria described
in this rev ion of NRC Bulletin 9101, Supplement 1. If you have any
questions abo
the information in this notice, please contact the technical
contact listed
low or the appropriate regional office.
Robert F. Burnett, Director
Division of Fuel Cycle Safety
and Safeguards
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
Jerry
th, NMSS, (301) 415-7156 Attachments:
1. List of Recently Issued NM
Information Notices
2. List of Recently Issued NRC nforation Notices
DOCUMENT NAME:
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v>
IN 94-XX
August
, 1994 Addres es are requested to review their criticality safety reporting
procedues to ensure that they meet or exceed the reporting criteria described
in this rvision of NRC Bulletin 9101, Supplement 1. If you have any
questions
out the information in this notice, please contact the technical
contact list d below or the appropriate regional office.
Robert F. Burnett, Director
Division of Fuel Cycle Safety
and Safeguards
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
Jerry
th, NMSS, (301) 415-7156 Attachments:
1. List of Recently Issued NMS Information Notices
2. List of Recently Issued NRC
formation Notices
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