ML033440504
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| ML033440504 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/08/2002 |
| From: | Smith K NRC Region 4 |
| To: | Nease R NRC Region 4 |
| References | |
| FOIA/PA-2003-0358 | |
| Download: ML033440504 (1) | |
Text
......
S From:
Karla Smith To:
Rebecca Nease Date:
1/8102 8:39AM
Subject:
Re: Backfit analysis
- Geary, Rebecca plans to revise the backfit response (analysis) based on the points below. Please let me know If you have any problems with this approach. I do not want her to get too far with this If you do not feel this Is the right approach. We are willing to talk with you about It If you think that Is necessary.
Thanks Karia Karda D. Smith RIV Regional Counsel 817-860-8271 (w) 817-860-8122 ()*
kdsl @nrc.gov
>>> Rebecca Nease 01/08/02 08:33AM >>>
- Karda, As we discussed (at length) yesterday, I will reorganize my ANO backfit argument in the following manner
- 1. Our position wrt Appendix R, li.G has always been that licensees must comply with III.G.2 or III.G.3 or get an exemption. This Is exemplified by numerous generic (SOC, GLs, INs) and ANO-specific docketed Information (SERs).
I
- 72. NRR requested (on the docket) that ANO list the fire areas (FAs) In which they credit manual actions.,
NRR reviewed and approved of the use of manual actions in 14 FAs. The 2 FAs which are the subject o our Inspection finding (98J and 99M) were not included in those 14 FAs approved for manual action.
aD i
3.In reading their backfit claiml
- 4. The criteria ANO described under v perform the manual actions and suffici
==
Conclusion:==
There was no backft, an Rebecca F.IiA-_
(X -)--
vhich they would take mar lent number of operators.4 Incd e to d ANO Is not In compliance with Appendix R,Section III.G.2.