ML20102B177

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Provides Results of Review of NSHC Package Re Snubbers. Objects to Issuing Spec in Present Form.Spec Legally Improper If Part of Tech Specs Change Can Only Be Made by Amend Modifying Tech Spec
ML20102B177
Person / Time
Site: 05000000, Diablo Canyon
Issue date: 12/12/1983
From: Scinto J
NRC
To: Schierling H
NRC
Shared Package
ML20102A920 List: ... further results
References
FOIA-84-166 NUDOCS 8502090112
Download: ML20102B177 (1)


Text

r-December 12, 1983 Note to H. Schierling

SUBJECT:

DIABLOCANYONSNUBBER,5(OELD#839711)

Larry has marked changes in the notice. This appears to look more than an admini-strative change and you should make the finding on the basis of each of the three criteria. Go through each one of them and describe why this change does not involvr any significant change of the type reflected in the three separate criteria. The second point is that if the applicant's incoming, in fact, requests a change in the snubber list the way you specify it, that is, the snubber list with the provision that says it can be modified pursuant to 50.59

- if that's what the applicant's incoming says, then notice it that way because that's what the applicant said. However I want to make it very clear that I intend to object to issuing a spec in that form. That is a legally improper specification.

If it is part of the technical specifications, the only way that it should be changed is by technical specification modification, that is an amendment. 50.59 is not the proper technique for modification of a pro-vision of the technical specifications.

I know that the Staff has done that in a number of cases and it is improper in all of those cases.

If that what's the applicant requested, that's what you should notice.

I want to make it very clear now that I intend to object when the final comes through on this one. This is improper.

Joe Scin o cc:

D. Brinkman W. Olmstead L. Chandler E. Case

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/db

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