ML20134E843
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l July 31, 1992 l
TO:
David Matthews, NRR/PDII-3 l
)
FROM:
Patrick Baranowsky, AEOD l
SUBJECT:
VOGTLE'S RESPONSE TO ENFORCEMENT ACTION 91-141T YOUR FAX TO ME, DATED JULY 28, 1992, AND THE DRAFT FAX TO LIEBERMAN l
Based on NRR's assessment, if it has been determined that by i
opening the valves the plant was in a condition outside its l
raaulatory damian hacia, as defined in 10 CFR 50.2 and also delineated in SECY-91-364, then this event or condition in reportable pursuant to 10 CFR 50.73 (a) (2) (ii) (B).
In addition you should note that violations of Technical Specifications are, reportable under 10 CFR 50.73 (a) (2) (1).
Thus, we believe that this NRC action is consistent with the reporting requirements and the ongoing dialogue with the industry.
Furthermore, in discussions that the NRC staff has had with industry representatives, it is agreed that the events / conditions outside the regulatory design basis are reportable, which include some but not all of those conditions outside the engineering
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design basis.
The issue of reportability.of events / conditions l
outside the plant licensing basis has not yet been resolved, b
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