ML20213F353
| ML20213F353 | |
| Person / Time | |
|---|---|
| Issue date: | 06/24/1985 |
| From: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Bemis P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20213E720 | List: |
| References | |
| FOIA-86-729 NUDOCS 8507010299 | |
| Download: ML20213F353 (1) | |
Text
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JUN 24 995 MEMORANDUM FOR: Paul R. Bemis, Director Division of Reactor Safety Region II FR0!k: Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
SUBJECT:
INTERPRETATION OF 10 CFR 50.59 AND 50.72 This refers to your memorandum to me on this subject dated May 30, 1985.
In general, we agree with your interpretation of the regulations; however, the following comments should clarify our position.
With regard to the reportability under 10 CFR 50.72(b)(1)(ii)(B) of events that are "outside the design basis of the plant," the Federal Register notice that published this regulation states:
The intent of this paragraph is to capture those events where the plant, including its principal safety barriers, was seriously degraded or in an unanalyzed condition. . . . The Commission recognizes that the licensee may use engineering judgment and experience to determine whether an unanalyzed condition existed.
It is not intended that this paragraph apply to minor variat ons i in individual parameters, or to problems concerning single pi.tces of equipment.
Thus, a thermal overload trip device with a set point that is bounded by a safety analysis is, as you state, not in itself reportable unless another reporting criteria covers the event. On the other hand, if the set point for the thermal overload device invalidates a safety analysis, i.e., has a real potential for a safety consequence, then the deviation in set point is reportable.
tWnd 51c41livi E: 0 kidan Edward L. Jordan, Director Division of Emergency Preparedness
, and Engineering Response Office of Inspection and Enforcement cc: C. J. Heltemes, AE0D l DRP Division Directors, RI, RIII, RIV, RV .
Distribution:(withincoming)
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