ML20102A946

Provides Results of Review of NSHC Package Re Consolidation of Mgt Responsibilities.Returned W/O Oeld Concurrence Because Reasons Given for Conclusions Do Not Necessarily Follow from Stated Reasons

ML20102A946
Person / Time
Site:	05000000, Ginna
Issue date:	03/22/1984
From:	Goldberg J NRC
To:	Dick G NRC
Shared Package
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References
FOIA-84-166 NUDOCS 8502090013
Download: ML20102A946 (1)

Text

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3 n/s'y Note to:

George Dick From:

Jack Goldberg

SUBJECT:

.'GINNA AMENDMENT RE CONSOLIDATION OF MANAGEMENT RESPONSIBILITIES I realize that the attached amendment package has been pending for many months and that the amendment is relatively minor.

Nevertheless, I am returning it without ELD concurrence because the-reasons given for the conclusions on the three NSHC standards ~of 10 C.F.R. 6 50.92 do not support the conclusions; i.e., the conclusions (" Consequently,..."; "Therefore,...";

"Thsrefore,...") do not necessarily follow from the stated reasons.

What needs to be done to correct this is to state why the consolidation of responsibilities (1) "will not cause a significant increase in the probability o'r consequences of an accident, (2) will not create a new or different kind of. accident, and (3) does not significantly reduce the margin of safety.

For example, assuming the facts support it, something like the following might be used for the first standard:

"The consolidation of responsibility of the Superintendent does not affect the operation, per se, of the facility and will not

- affect the ro.le of the Superintendent er any other individual insofar as accident mitigation is concerned.

Therefore, there will be no significant increase in the probability or consequence of a previously evaluated accident if this consolidation is authorized."

Similar reasons could be stated for the second standard.

iFor the third standard, it could be stated, if true,' that the consolidation does not ~ involve any cnange to the plant systems hardware, tech spec's, limiting conditions,- etc. and therefore will not restit in a significant reduction in the margin of safetv.

If you have any questions, please call' me (x27619).

A/

ack Goldberg MW" swaggg0,13g40518 p

P TOS4-166 4

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