ML16209A045
| ML16209A045 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/26/2016 |
| From: | April Pulvirenti Plant Licensing Branch IV |
| To: | Entergy Operations |
| Pulvirenti A | |
| References | |
| CAC MF6366, NCP-2016-012 | |
| Download: ML16209A045 (13) | |
Text
NCP-2016-012 Section C As the NCP Approver, I have read and considered the submission from EEEB staff. Prior to discussion of the issues, I would like to acknowledge the work of the EEEB staff and recognize that it is good that they are exercising their ability to register their concerns through the NRCs non-concurrence process.
Summary of Issues The EEEB staff is objecting to the issuance of the amendment to the Waterford license to implement TSTF-425 (Risk-Informed Surveillance Frequencies). The EEEB Non-concurrence has four core objections to the proposed license amendment request (LAR):
- 1. The proposed amendment would modify the NMP Technical Specifications (TSs) in a manner that doesnt meet the current licensing basis of NMP and NRC regulatory requirements. Specifically, General Design Criterion (GDC) 17, GDC 18, 10 CFR 50.36(c)(3), and 10 CFR Appendix B Criterion III.
- 2. The Topical Report (TR) Safety Evaluation (SE) was not reviewed by the Office of the General Counsel (OGC).
- 3. There are no backstops provided for the Surveillance Requirement (SR) frequencies that would be relocated to the licensee controlled document.
- 4. The proposed amendment is risk-based, not risk-informed.
Evaluation of Non-Concurrence The objections raised in this non-concurrence are identical to those raised by EEEB staff during the NRC review of a TSTF-425 LAR for the Perry Nuclear Power Plant, Unit 1 (NCP-2015-012).
The non-concurrence, including the NRCs response to the non-concurrence is available under Agencywide Documents Access and Management System Accession No. ML16033A197. As no new issues have been raised by the current non-concurrence, nor has additional technical justification for the issues been provided, I find that the previous resolution of the issues remains valid. Thus, the NRC staff should proceed with issuance of the LAR.