ML13324A774
| ML13324A774 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/21/1985 |
| From: | Hebdon F, Jordan E NRC Office for Analysis & Evaluation of Operational Data (AEOD), NRC/IE |
| To: | Ray H Southern California Edison Co |
| References | |
| NUDOCS 8511140414 | |
| Download: ML13324A774 (2) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 OCT 2 1 1985 Harold B. Ray Vice-President and Site Manager San Onofre Southern California Edison Company P. 0. Box 128 San Clemente, California 92672
Dear Mr. Ray:
Thank you for your letter of August 19, 1985. We are pleased that we could be of service, and we look forward to future opportunities to work with you.
Several of the comments included in your letter regarding possible future rulemaking will be taken into account when such rulemaking is undertaken.
We would like to comment on some of the issues contained in the attachment to your letter. In regard to item I, "10 CFR 50.36 Reporting Requirements," you assert that if the.10 CFR 50.36 condition did not constitute a report pursuant to §50.72, only a 30-day Licensee Event Report pursuant to §50.73 would be required. This is'an over'simplification of the guidance that we provided at the workshop. There are requirements in §50.36 to notify the Commission, via the Emergency Notification System (ENS), when a safety limit or limiting safety system setting is exceeded. I believe the guidance you are referring to was that simply entering a limiting condition for operation (LCO) did not require an immediate notification via the ENS.
In regard to item II, "Reporting of Spurious Actuations of Engineered Safety Features Under 10 CFR 50.72(b)(2)(ii) and 50.73(a)(2)(iv)," we welcome your insights, and we are contemplating rulemaking that would eliminate unnecessary reporting from §§50.72 and 50.73.
In regard to item III, "Starting the Reportability Clock," we take exception to the view that the reportability clock should start only when a cognizant engineer or supervisor has determined that a reportable condition exists.
This is a complicated subject that is discussed in detail in NUREG-1022, Supplement 1, "Licensee Event Report System," question 2.5 and section 14.
In regard to item IV, "Reporting Requirement for Radioactively Contaminated Persons," we agree with the stated interpretation.
In regard to item V, "Suggested Changes to 10 CFR 50.72," we will give your comments careful consideration in any future rulemaking.
8511140414 851021 PDR ADOCK 05000206 P
Harold B. Ray 2
In regard to item VI, "Material False Statement vs. Error in Reporting," as you are probably aware, the Commission and the Advisory Committee on Enforcement Policy are considering whether changes to the Commission's policy regarding material false statements should be made. Your comments will be taken into account by the staff during its deliberations on this matter.
In regard to item VII, "Counting LER's," we agree that simple counts of LER's are not useful.
Only careful analysis of LER's will yield valid results.
Sincerely, OUnal Signed By, F-i Jordan Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Niginall sigrned 8y fredpr
Fredrick J. Hebdon, Chief Program Technology Branch Office of the Analysis and Evaluation of Operational Data Distribution:
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Regional Administrators
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