ML20211M325
| ML20211M325 | |
| Person / Time | |
|---|---|
| Issue date: | 02/16/1982 |
| From: | Mcdonald J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Quick D NRC |
| Shared Package | |
| ML20209B956 | List: |
| References | |
| FOIA-86-729 NUDOCS 8612170121 | |
| Download: ML20211M325 (2) | |
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UNITED STATES !
!" n NUCLEAR REGULATORY COMMISSION !
E E REGION 11 '
FEB 1 6 1982 SSINS 0330 MEMORANDUM FOR: D. R. Quick, Chief, Reactor Projects Section 1A, RRPI Division FROM: J. A. Mcdonald, Senior Resident Inspector, Watts Bar
SUBJECT:
PROPOSED CHANGES TO 10 CFR 50 Proposed changes to the imediate reporting requirements of 10 CFR 50.72 were published in the Federal Register on December 18, 1981. The fourth proposed example of an immediately reportable instance deals with the potential for unavailability of a safety function. It reads as follows:
- 4. Any instance of personnel error, equipment failure or discovery I of design or procedural inadequacies that alone could prevent ful-fillment of the safety function of those structures, systems, or components needed to (i) shutdown the reactor and maintain it in a safe shutdown condition, (ii) remove residual heat or (iii) control the release of radioactive material.
The stated causes for the potential unavailability are limited to personnel error, equipment failure, design inadequacies, and procedural inadequacies.
The exclusion of construction deficiencies from this reporting requirement could mislead licensees to believe the Commission does not consider there to be a direct relationship between the quality of nuclear power plant construction and the acceptability of its operation.
! It is recommended that the following wording be used for this reporting l
requi rements.
- 4. The discovery of an operation, design, or construction error or procedural inadequacy that alone could prevent fulfillment-of the safety function of those structures, systems, or com-ponents needed to (i) shutdown the reactor and maintain it in a safe shutdown condition, (ii) remove residual heat or (iii) control i the release of radioactive material.
l My use of the terms operation, design and construction is intended to encompass these activities important to safety for which assurance of l quality is required by 10 CFR 50, Appendix S. These activities include
! designing, purchasing, fabricating, handling shipping, storing, cleaning, erectir.g, installing, inspecting, testing operating, maintaining, report-ing, refueling and modifying.
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.E D. R. Quick. FEB 2 6 1932
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I ~am available for any discussion of this matter at 615-365-5487.
J J. A. cDonald ,
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