ML17109A134
| ML17109A134 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/19/2017 |
| From: | Ed Miller Plant Licensing Branch II |
| To: | William Gideon Duke Energy Progress |
| Hon A, NRR/DORL/LPL2-2, 415-8480 | |
| Shared Package | |
| ML17109A132 | List: |
| References | |
| NCP-2017-006 | |
| Download: ML17109A134 (5) | |
Text
NCP-2017-006 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 Brunswick 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 Brunswick Technical Specifications (TSs) in a manner that doesnt meet the current licensing basis of Brunswick 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.