ML18151B054

COL Docs - NRC Comment on Uin for ITAAC Index No. 872

ML18151B054
Person / Time
Site:	Vogtle
Issue date:	05/31/2018
From:	NRC
To:	NRC/NRO/DNRL/LB4
References
Download: ML18151B054 (2)

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Vogtle PEmails From: Hoellman, Jordan Sent: Thursday, May 31, 2018 3:48 PM To: Vogtle PEmails

Subject:

NRC Comment on UIN for ITAAC Index No. 872 Comment on UIN for ITAAC Index # 872 In the first paragraph (last sentence) of the ITAAC Completion Description section of Notice of Uncompleted ITAAC Letter No. ND-18-0637 (May 11, 2018), for ITAAC No. E.3.9.08.01.03 (Index No. 872), SNC states:

Offsite deficiencies as used in this ITAAC are considered to be Level 1 Findings, Level 2 Findings, and Plan Issues as defined in FEMA P-1028, Federal Emergency Management Agency (FEMA) Radiological Emergency Preparedness Program (Reference 1).

In addition to the reference to FEMA P-1028 (i.e., FEMA P-1028, Program Manual - Radiological Emergency Preparedness, January 2016), the UIN should also reference FEMAs May 15, 2015, Memorandum from Andrew Mitchell (Director, Technological Hazards Division (THD)), to Radiological Emergency Preparedness Program (REPP) Staff, Regional Assistance Committee (RAC) Chairs, and Federal Preparedness Coordinators (FPCs);

Subject:

New Terms to Classify REPP Exercise-Related Observations and Issues. (See ADAMS Accession No. ML18138A258). The reference to this FEMA memorandum is necessary because it provides the direct connection between a Level 1 Finding and a Deficiency classification (offsite deficiencies is the term used in ITAAC No. E.3.9.08.01.03, Index No. 872, Acceptance Criterion 8.1.3).

FEMAs May 15, 2015, memorandum specifically states (in part) that Level 1 Findings will have the same requirements as the current Deficiency classification, while Level 2 Findings and Plan Issues will be afforded additional HSEEP-compliant avenues for resolution. Given this direct correlation between Level 1 Findings and Deficiencies, as well as the definition of Level 1 Findings (in both the FEMA memo and P-1028), the correlation of deficiencies with the new FEMA classifications (indicated above) should be limited to Level 1 Findings only. This is due to the importance of FEMA deficiencies (now Level 1 Findings), with regard to the protection of the health and safety of the public living in the vicinity of a nuclear power plant.

A suggested revision to SNCs letter (quoted sentence above) is: Offsite deficiencies as used in this ITAAC are considered to be Level 1 Findings, as defined in FEMAs January 2016 Program Manual - Radiological Emergency Preparedness (FEMA P-1028), and as addressed in FEMAs May 15, 2015, Memorandum, entitled New Terms to Classify REPP Exercise-Related Observations and Issues.

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NRC Comment on UIN for ITAAC Index No. 872 Sent Date: 5/31/2018 3:48:04 PM Received Date: 5/31/2018 3:48:07 PM From: Hoellman, Jordan Created By: Jordan.Hoellman2@nrc.gov Recipients:

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