ML20214G404

Advises That Circumstances Associated W/Lack of Reporting RPS Actuations Described in 860226 Memo,Though Reportable Per Strict Interpretation of 10CFR50.72 & 50.73 & NUREG-1022,do Not Require Further Enforcement Efforts

ML20214G404
Person / Time
Site:	Peach Bottom, 05000000
Issue date:	05/13/1986
From:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20213E720	List: ML20213E718 ML20213E733 ML20213E739 ML20213E785 ML20213E807 ML20213E863 ML20213F021 ML20213F065 ML20213F105 ML20213F172 ML20213F353 ML20214G404 ML20214R668 ML20214R771 ML20214R782 ML20214R804 ML20214R848 ML20214R880 ML20214R914 ML20214S037 ML20214T165 ML20214T277
References
FOIA-86-729, RTR-NUREG-1022 NUDOCS 8605200436
Download: ML20214G404 (1)

Text

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MEMORANDUM FOR:

Richard W. Starostecki, Director Division of Reactor Projects, Region I FROM:

Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement

SUBJECT:

REPORTABILITY UNDER 10 CFR 50.72 AND 50.73 Your memorandum of February 26, 1986 discussed a Notice of Violation at the Peach Bottom Atomic Power Station.

It provided the licensee's position and your position concerning the reportability of RPS actuations in a reactor that has been defueled.

You suggested that the results of IE and AE00 reviews be dissem-inated through an information notice in order to assure a consistent position.

We have reviewed the circumstances associated with the lack of reporting that you described in your memorandum dated February 26, 1986.

In looking at your position; we agree that a strict interpretation of 10 CFR 50.72 and 50.73 and the guidance in NUREG 1022 would say that the events are reportable.

However, we would not support further efforts at enforcement of this aspect.

NUREG 1022 allows non-reporting of safety system actuations when the safety system has been made inoperable.

Your position is basically, that defueling the reactor does not make the scram system inoperable and, therefore, scram actuations must be reported even though there is no core present. However, it does not make sense to require reporting of spurious actuations of the RPS when the reactor is defueled unless there is some safety significance to the actuations.

It is for similar reasons that the regulations do not require spurious actuations of engineered safety features that are out of service.

Consequently, unless there some safety significance associated with the spurious RPS actuations, we would not support further efforts on enforcing the reporta-bility of spurious RPS actuations when the reactor is defueled.

This position has been coordinated with AE0D.

If you have any questions or comments, please contact us.

Utisinal5!gn.3giy E: Dhk Edward L. Jordan, Director Divisien of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement cc:

F. Hebdon, AE00 G. Holahan, NRR ni zek D GR

Contact:

E. Weiss, IE 492-9005 Distribution:

DCS EAB /F DEPER R/F eiss DAllison EJordan SSchwartz RVollmer JMTaylor DEPER 86-55

[,ER:IE AE0Dd.

• See Previous Concurrence mD

• EAB:DEPER:IE

• EAB:DEPER:IE *DD:DEPER:IE EWeiss:ew DAllison SASchwartz ELJordan FHebdon

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