ML20214M820
| ML20214M820 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/04/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8609110301 | |
| Download: ML20214M820 (2) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ot SN 157B Lookout Place Cj cp SEP 4 986 c,
c0 C3 U.S. Nuclear Regulatory Conunission Region II p
ATTN:
Dr. J. Nelson Grace, Regional Administrator op 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE REGION II INSPECTION REPORT 50-327/86-36 AND 50-328/86 CLARIFICATION OF RESPONSE TO VIOLATION Because of a misinterpretation by the SQN Site Licensing Staff of internal information, the original response to this violation indicated that the surveys for the top surfaces for shipments SNP-428 and SNP-430 were performed but not documented. The standard procedure at Sequoyah is for the Site Licensing Staff to request informal input to responses to violations from the applicable responsible plant section. This information is then edited into a formal response to NRC and then routed through an internal concurrence chain.
The informal input for violation 86-36-01 was provided by the plant Radwaste Section. The portion of this input which was misinterpreted read as follows:
Further investigation showed that we had performed the top surface reading as required but a revision to the procedure had deleted this performance as un-necessary by declaration of the top portion of the van trailer being in-accessable.
The formal response was prepared and concurred with by the Radwaste Section.
The Site Licensing Manager, later in the concurrence chain, questioned the adequacy of the response (this revision is unavailable) and had some rewording performed. The final version as submitted to NRC read as follows:
Further investigation into the violation has verified that the surveys for the top surfaces were performed but not documented because of the revised data sheets.
This sentence clearly states the Site Licensing Staff's interpretation of the informal input supplied by the Radwaste Section. Another Sequoyah policy is to not require reconcurrence by all parties unless the intent of the response has changed. An attempt was trade to recoordinate the change with the originating individual, but was not considered essential since the change was not considered to alter the intent of the response. The originating 9
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. individual had gone on annual leave and would not be available before the response due date. Since the individual's immediate supervisor was also not available, and the reconcurrence was not considered essential, reconcurrence from the originating section was not obtained. The original concurrence sheet was, therefore, continued in the concurrence chain.
The actual intent of the statement was to inform NRC that the top surveys had been done on past shipments but had been terminated when the procedure was revised to delete the top survey requirement. This was an error in interpretation of TVA internal information and in no way was meant to mislead or misrepresent the actual facts of the violation.
To prevent this from occurring in future submittals, any changes made to NRC correspondence will be rerouted back to the originating individual or a responsible supervisor knowledgeable on the particular subject for concurrence.
If you have any questions, please get in touch with M. R. Harding at (615) 870-6422.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY
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ridley Director Nuclear Sa ty and Licensing cc Mr. James Taylor, Director office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i
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