05000302/LER-1986-007, Forwards LER 86-007-00.Wording of 10CFR50.72 & 50.73 Makes No Provision for Reporting Suspected or Possible Conditions.Enforcement Guidance Should Closely Reflect Literal Interpretation of Regulation

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Forwards LER 86-007-00.Wording of 10CFR50.72 & 50.73 Makes No Provision for Reporting Suspected or Possible Conditions.Enforcement Guidance Should Closely Reflect Literal Interpretation of Regulation
ML20211K361
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 06/20/1986
From: Eric Simpson
FLORIDA POWER CORP.
To:
NRC OFFICE OF ADMINISTRATION (ADM)
Shared Package
ML20211K364 List:
References
3F0686-17, 3F686-17, NUDOCS 8606270384
Download: ML20211K361 (2)


LER-2086-007, Forwards LER 86-007-00.Wording of 10CFR50.72 & 50.73 Makes No Provision for Reporting Suspected or Possible Conditions.Enforcement Guidance Should Closely Reflect Literal Interpretation of Regulation
Event date:
Report date:
3022086007R00 - NRC Website

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Floskia Power C OR POR ATION June 20, 1986 3F0686-17 Document Control U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Licensee Event Report No. 86-007-00

Dear Sir:

Enclosed is Licensee Event Report (LER) No. 86-007-00 which is submitted voluntarily by Florida Power Corporation (FPC).

This report is being submitted as a result of an apparent interpretation of 10 CFR 50.72 and 50.73 made in Inspection and Enforcement Manual Temporary Instruction 2515/75, Section 2515/75-07. This section implies that report-ing is required if documentation of environmental qualification is not available. No consideration is given to actual capability of the equipment in question to withstand a harsh environment or the probability that the equipment will fail under accident conditions. This appears to be beyond the scope of 10 CFR 50.72(B)(2)(III) and 10 CFR 50.73(A)(2)(V) which require reporting of "Any event or condition that alone could have prevented the fulfillment of the safety function. . .". The wording of the rul e makes no provision for reporting of " suspected or possible" conditions. FPC hopes that enforcement guidance will, in the future, more closely reflect a literal interpretation of the regulation.

l 86062703G4 860620 PDR ADOCK 00000302

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GEN ERAL OFFICE 3201 Thirty fourth street south e P.O. Box 14042, St. Petersburg, Florida 33733 e 813-866-5151

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June 20, 1986 3F0686-17 i Page 2 I

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t Should there be any questions, please contact this office,

! Sincerely, ,

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i E. C. Simpson Director, Nuclear Operations

! Engineering and Licensing l

I AEF/feb i i Enclosure i

xc: Dr. J. Nelson Grace i Regional Administrator, Region II 1

, U.S. Nuclear Regulatory Commission ,

j 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323 l

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