ML20217E641

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Discusses Real Issues with Attaching TIA & Response That Some Licensee Documents Were Attached to TIA
ML20217E641
Person / Time
Issue date: 07/21/1999
From: Kugler A
NRC (Affiliation Not Assigned)
To: Shawn Campbell
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20217E572 List:
References
FOIA-99-323 NUDOCS 9910200029
Download: ML20217E641 (1)


Text

E ' [ A'x1rew Kugler . Re: St.BidDG 11 Violation Paga1 l From: Andrew Kugler (tJNL

To: Stephen Campbell

. Wed, Jul 21,199911:28 AM

( A.E I)

Date:

Subject:

Re: SLB/ EDG 11 Violaton The only real issue i see with attaching the TIA and its response is that there were some lichnsee documents attached to the TIA. We should be sure they don't object to them becoming public. The TIA response is flagged as prodocesional However, I believe the release of this document as part of a final NRC public document (i.e., the inspecton repo1) removes the predecisional nature of the response. If wp

'want to avoid the panic that could ensue when people see pages with "Predecisional" top & bottom, we might just want to import the text of the response into an attachment to the IR.

In terms of the extent of the list of equipenent affected by TS 3.8.1.1.c, yes, it is very large and other licens es have had to deal with that. Examples I have heard included items such as radiation monitors.

But that is what the TS says. The STS handle it better in that the licensee's acton is to consider both trains of the affected system inoperable and take the acton for that system. ,

AMy

'X2828 -%

+. >>> Stephen Campbell 07/2111:11 AM >>>

' Debrifed the licensee that this will be proposed as a potential violation. They were unable to give me their position because they do not have the TIA or the NRR response in front of them. They said they were not

, at liberty to discuss their position on the violation and will have an opportunity to discuss this in their response to the violation. Therefore, it appears they will not properly characterize this issue in the corrective acton program without having these documents. Recommend that we cite the violation with the TIA and NRR response as an attachment to the report.

Further, the licenses stated that if NRRs position is true, their list of equipment required to meet TS 3.8.1.1.c would be extensive if they were to include containment isolation valves and leak detecten systems, systems required by TSs.

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