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Based on increasing conductivity in the reactor vessel and condenser hotwell, a power reduction was initiated from 100 percent power. A manual scram was inserted at 57 percent RTP and 49 percent Core Flow based on Chemistry recommendations due to sulfates and chlorides in the hotwell. Following the scram a reduction in reactor water level to -28 inches resulted in a Primary Containment Group 2 Isolation (ESF) occurring. All isolations and systems responded as expected. Current plant status is Hot Shutdown with plans to proceed to cold shutdown. All control rods fully inserted and decay heat is being removed with the bypass valves into the condenser. The licensee notified the NRC Resident Inspector.

• * * RETRACTION FROM SHIFT SUPERVISOR (TONY SPRING) TO ABRAMOVITZ AT 16:33 ON 6/6/2005 * * *

After further review and evaluation it has been determined that the four hour call made May 23, 2005 per the guidance of 50.72(b)(2)(iv)(B) should be retracted. A review of the event with respect to NUREG 1022 Revision 2 determined that: The manual scram was part of a pre-planned sequence to shut the plant down due to an equipment problem. The manual scram was part of a pre-planned sequence. The guidance to scram the reactor was established by the plant's Abnormal Operating Procedure addressing a condenser tube leak and was part of a preplanned sequence to prevent future equipment and component failures. The Manual Scram was not inserted to protect the plant against an event that presented a challenge to an FSAR analyzed event. In other words, this was not an Anticipated Operational Occurrence, an Accident, or a Special Event as defined in section 15.1.3 of the Unit 2 FSAR. Rather it was part of a plan to shutdown the reactor to protect against future potential equipment problems due to out of limits chemistry parameters. Further justification is provided by the fact that the manual scram was not initiated in anticipation of an automatic scram. Per NUREG 1022 Rev. 2: 'The staff also considers intentional manual actions, in which one or more system components are actuated in response to actual plant conditions resulting from equipment failure or human error, to be reportable because such actions would usually mitigate the consequences of a significant event. This position is consistent with the statement that the commission is interested in events where a system was needed to mitigate the consequences of the event.' However, the reporting requirement itself indicates that actuations that result from pre-planned sequences are not reportable. An example is provided in the NUREG of an equipment problem involving the loss of recirc pumps. In this example it is stated that: 'Even though the reactor scram was in response to an existing written procedure, this event does not involve a preplanned sequence because the loss of the recirc pumps and the resultant off-normal procedure entry were event driven, not pre-planned.' This is similar to our event, however, in the NUREG example, the reactor is scrammed to protect against the possibility of a stability event and stability is an FSAR analyzed event. In our case we were shutting down for chemistry reasons, not an FSAR type event. It is concluded that when the RPS is used to shutdown the reactor as part of a plan for the resolution of equipment problems, and the RPS is not needed to mitigate the consequences of an FSAR analyzed event, i.e., one which threatens a fission product boundary (i.e., fuel cladding, RCPB, primary and secondary containments), the RPS actuation is not reportable under 50.72(b)(2)(iv)(B).

The licensee notified the NRC Resident Inspector. Notified R2DO (Haag).

• * * RETRACTION RESCINDED - S. BURTON TO M. RIPLEY 1524 EDT 06/08/05 * * *

On May 23, 2005 a four hour report was made per the guidance of 50.72(b)(2)(iv)(B), 'Any event or condition that results in an actuation of the RPS when the reactor is critical except when the actuation results from and is part of a pre-planned sequence during testing or reactor operation.' This was made per event # 41725. The report was made within the four hour time frame of 10 CFR 50.72(b)(2). The four hour report for event # 41725 was retracted on June 6, 2005. After further consideration, the retraction made on June 6, 2005 is being cancelled and the original report re-instated. The licensee notified the NRC Resident Inspector. Notified R2 DO (K. Landis)