IA-99-323, Discusses Agreement to Fermi Action with Respect to Violations
| ML20217E750 | |
| Person / Time | |
|---|---|
| Issue date: | 05/06/1999 |
| From: | Kugler A NRC (Affiliation Not Assigned) |
| To: | Shawn Campbell, Anton Vegel NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20217E572 | List: |
| References | |
| FOIA-99-323 NUDOCS 9910200056 | |
| Download: ML20217E750 (3) | |
Text
Andrew Kugler - R2 3.0.3 pg1 From:
To:
Andrew Kugler bk Anton Vegel, Stephen Campbell ( /Gb Date: Thu, May 6,1999 7:06 AM
Subject:
Re: 3.0.3 i tend to agree. I have seen Fermijn action with respect to violations and they would likely use a weak argument in one area to weaken the whole issue. Since the 3.0.3 issue is vague at best, we sh,ould probably stay focused on the clear areas of violation.
Andy
- X2828 n> Stephen Campbell 05/05 5:16 PM >n Here's a thought. If they' entered 3.0.3 upon discovery, this would have allowed additional time to begin the shutdown. For example, they'd wait 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and begin shutdown per 3.0.3 to reach 6,6,12 SD statements vice beginning an immediate SD per TS 3.8.1.1.c. It appears that immediate SD is a more conservative decision from a timeframe perspective. Nevertheless, if I would pick the battle, it would be allowing the EDG 11 outage to begin given that SLC was inoperable that led to the more significant issue of a TS violation. This was missed by multiple layers of management and operators. It appears that making anjssue on sn unclear interpretation would cloud the larger issue.
>n Andrew Kugler 05/051:22 PM >
Steve / Tony, I have to leave in a little while and couldn't reach you by phone. Here's the feedback I got from TSB.
Per the TS, it isn't absolutely clear whether you enter 3.0.3 or not. However, TSB considers this a reasonable approach. They raised the example that the plant is ten minutes from the end of the 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> allowed to get to cold shutdown when they realize they messed up. Obviously they can't get there in ten minutes. So, entry into 3.0.3 is reasonable to allow time for an orderly (and safe) shutdown. However, TSB also stated that we would expect the licensee to shut down expeditiously - i.e., no sitting around waiting to see if the problem could be fixed. They should commence the shutdown as soon as possible.
i All that said, my read on this is that if we want to make a reali<.ssue out of this, we may need to bring in OGC to get a legal (i.e., binding) interpretation. I'm not sure the TSB interpretation would hold up in court.
One way we might be able to make it stand would be that they are in 3.0.3 and the 3.8.1.1 Action Statement too. Therefore, in addition to satisfying 3.0.3, they should be making every effort to meet the action statement. The bottom line is that there is not an absolutely clear answer. The best approach right now might be to let them teli us what they believe, question them really hard about it, and then take it back here and mull it over.
I'm afraid I haven't been as helpful as I would have hoped.
Andy X2828 9910200056 991014 PDR FOIA l CHAPMAN 99-323 PDR
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