ML20127L757
| ML20127L757 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/24/1984 |
| From: | Rogers W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20127L745 | List: |
| References | |
| NUDOCS 8506280120 | |
| Download: ML20127L757 (2) | |
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UNITED STATES
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NUCLEAR HEGULATORY COMMISSION
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cLEN ELLYN, ILLINOIS 60137 JUL 2 4 GS4 MEMORANDUM FOR:
C. E. Norelius, Division Director FROM:
W.
G.. Rogers, Senior Resident Inspector THPU:
D..Shafer, Branch Chief
SUBJECT:
PROFESSIONAL DIFFERING OPINION ON INTERPRETATION I
'OF TECHNICAL SPECIFICATION e
r Tol'edo E' ison experienced a loss of one of its on'.Tanuary 11, 1984,.
d vital buses as identified in Technical Specification 3.8.2.1.
The licensee declared the bus inoperable until the bus was re-energized from a non-Class lE power source.
Once re-energized, the licensee
. declared the bus operable.
Once I determined that the vital bus was being powered from a non-Class lE power source, I discussed the situation with my section chief. He upheld my initial concerns that the bus was in fact inoperable.
The licensee was informed that the bus was inoperable. unless power from a Class lE power source. The licensee agreed to comply with the NRC interpretation until the, matter was resolved.
e Based on this event,' a memorandum was' written from you to D..G.
Eisenhut to provide a NRR position on bus operability to enable the Region -to assure licensees are uniformly dealing with this matter in a manner consistent with NRC policy.
On May 30, 1984, D. G. Eisenhut responded that Technical Specification
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3.8.2.1 is not applicable if a' vital bus is powered from a.non-Class 1E power source.
-I. disagree with this interpretation. It is not consistent with-Technical Specification definition of operability as stated in Section 1.6.
Also, it alloes a licensee to operate or side tnc original' 5esign envelep of P CFI. 50 Ary:. dix A :ndefinitely.
Tn c..w:me c f May 15. 1954, f : ::- L. S. F. ::.in.= e r:. te 3.
- 2. La:nas explains the saf ety censequences cf tr.:s epratin;: : ce.f. ;r.:r a t i on.
Specificall,11 Lase :.cte the :.s t s e r. ten ce in the r econd par a g rapr..
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E Jul, 2 4 1984 a
I am unaware.that the Connission, except in Technical Specification Limiting Conditions of Operations action statements, allows a licensee to operate a facility outside of the single failure criteria defined in 10 CFR 50 Appendix A.
Finally, the definition of operability requires the availability
- of an emergency power source. At this and any other facility, this source is ultimately the diesel generator, not an offsite power line.
As such,.I consider this interpretation would allow a licensee to operate a nuclear facility far below acceptable safety margins and not consistent with Commission Regulations.
- After review of-this situation, I hope that.you will also challenge
, this interpretation.
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. Walt Rogers Senior Resident Inspector cc:
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