ML051220379

E-Mail from Ogle to Franovich, Draft Shearon Harris Fire Protection IR

ML051220379
Person / Time
Site:	Harris
Issue date:	11/03/2003
From:	Ogle C NRC/RGN-II
To:	Rani Franovich Office of Nuclear Reactor Regulation
References
FOIA/PA-2004-0277
Download: ML051220379 (2)

Text

LRani Franovich - Re: Fwd: DRAFT Shearon Harris Fire Protection IR . . Ed . ... . . w _ .

From: Charles R. Ogle To: Franovich, Rani By Date: 11/3/03 7:33AM

Subject:

Re: Fwd: DRAFT Shearon Harris Fire Protection IR Rani, thanks for the response.

I think that the underlying issue for URI 2-11-05 involves how to deal with manual actions which the licensee has substituted for one of the established protection schemes of III.G.2 of Appendix R.

The program office has told us that if we identify manuals actions which are feasible per the guidance in the inspection procedure, we are to issue a green NCV.

I think OE is concerned about this blanket approach and the fact that we are soon to issue enforcement discretion for this topic as part of the rulemaking. OE has suggested that we issue a green finding and keep the URI open. The URI would be closed once the NRC issues enforcement discretion.

One of the concerns that I have is that the revised inspection guidance for manual actions, may be more stringent than the existing guidance. Also, I am concerned about the message it sends to the licensee to say that we close the URIs and issue a green NCV for the manual actions we don't find feasible but are keeping the URI open for the manual actions we find feasible.

The question for NRR is: Will we be required to reinspect the manual actions at Harris if and when the revised criteria for manual actions are issued. ?

Thanks.

5

>>> Charles R. Ogle 10/31/03 07:37AM >>>

I suspect that the discussion on this will lapse into next week.

>>> Rani Franovich 10/31/03 07:20AM >>>

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today or can it wait until next week)?

Rani

>>> Charles R. Ogle 10/30/03 04:45PM >>>

Here is the draft report and the report that opened the 9 URIs. Right now the concern is how to handle the manual actions that we found acceptable per the current guidance (URI 2-11-05) . I think we are in agreement on the handling of the other 8 URls.

OE is proposing that this URI be left open, pending development of the revised manual action guidance associated with rulemaking. I am concerned about the implications that this has for followup inspection.

Thanks.

CC: Casto, Charles; Christensen, Harold; Nelson (HQ-OE), David; O'Donohue, Kathleen; Schin, Robert

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