ML040050099
| ML040050099 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 05/02/2003 |
| From: | Koltay P Office of Nuclear Reactor Regulation |
| To: | Nease R NRC Region 4 |
| References | |
| FOIA/PA-2003-0358 | |
| Download: ML040050099 (1) | |
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_. I..I. I Page From:
Peter Koltay/ A4-)Z-/Z,.
To:
Rebecca Nease eIl/
Date:
5/2/03 8:41 AM
Subject:
Re: IP71 111.05 - manual actions ok, so bit complicated and at the edge of the process, yes the finding should be entered into the CAP indicating a concern of very low safety siginificants, the compensatory measure in affect is the manual action process which reduced a potentially significant violation to a Green. this in not unlike posting a fire watch at a failed barrier, the failed barrier may represent a potentially significant safety issue. by placing a f ire watch we did not totally compensate for the barrier. I do'not want to argue the merits here.. with the tools and processes we have this is the best temp. solution while waiting for the Commission approval on the rule making which will be followed by enforcement discretion in this area. than we can close the greens we opened.
peter
>>> Rebecca Nease 05/01/03 08:59AM >>>>
- Peter, Now we know (thanks to your help) that when the IP sas to issue a Green Finding (when a licensee has credited mianual actions for meeting lll.G.2) LTabrings up a couple of other questions.
an httoea pel'~b Let's say that we found the licensee takes manual actionsanththoectnspertob prcduralized, reasonable, and feasible. According the IP we have a Gree Finding Hoeefor us to characterized a non-compliance as an NCthe licensee must ave ente oncompliance into their CAP and (so that we don't have a current safety concern) the licensee must also have taken some immediate compensatory measures until they complete their CAs.
I. Given the fact that the NRCIs going thru rulemaking to allow these manual actions, what exactly do we expect the licensee to do wrt entering the Item into the CAP, and putting In place comp measures?
- 2. If the licensee does NOT enter the Issue Into their CAP and take compensatory measures, can we still call In an NCV, or Is It a cited violation?
M-Oi.~r~cid WaS d:oe wth the FreadornO normaio
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