ML20102B260
| ML20102B260 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Surry |
| Issue date: | 10/12/1983 |
| From: | Gray J NRC |
| To: | Neighbors D NRC |
| Shared Package | |
| ML20102A920 | List:
|
| References | |
| FOIA-84-166 NUDOCS 8502090149 | |
| Download: ML20102B260 (2) | |
Text
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p, October-12, 1983 Note / o:'
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From:
J. Gray
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SUBJECT:
?SURR -1 AMENDMENTS REDUCING BORON CONCENTRATION OELD has:been asked to concur in a d
i d preliminary no tsignificant' hazards consideration (propose.not ce anNSHC) finding for a license amendm
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! reducing the minimum boron concentration in the Surry-1 boron injection (tank from 11.5% to 0%.and in the boric acid system from 11.5% to 7%.
1 JBecause I don'.t-believe we have provided an adequate basis for the proposed NSHC finding, I_ am not prepared to concur at this time.
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The problems' I have.are twofold.
First, the notice states that the
- amendment. falls within example (vi) of actions likely to involve NSHC Jyetsthere is no' showing at.all that this: amendment involves an action
-!which, while Lpossibly increasing the probability or. consequences of an accident or: reducing a safety margin, nevertheless meets all acceptable.
~ 'c'riteria.with, respect to a system or. component specified in the. Standard
' Review Plan. -The conclusory statement that "the staff has reviewed-and
- approved'a numberfof plants _as'_ meeting the acceptance criteria" doesn't
, appear <to have Lany relationship to anything involved in this amendment
- andl surely doesn't show that example (vi) applies for this specific.
amendment for this = particular ' plant.
If you are going to contend that example (vi)Mapplies, you must show clearly.in.the-notice why that is so.
-Second; you cite! example (iii)iof actions likely to involve SHC and then state:that it is not applicable.here because of compensatory actions the
' licensee-will;take.
However, you can'.t create new examples of actions
- likely to. involv'e-NSHC by.~ modifying:the Connission's examples of actions 1
Tlikely to involve.SHC?and the discussion involving example (iii) does
'not provide a basis, of'itself, for finding that'the instant license:
amendment involves NSHC.
If there are enforceable compensatory measures-Ltaken that'will insure that this' amendment will not. (1) significantly
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' increase the: probability / consequences of previously: considered accidents, 2 _
f(2) create'a' new and;different accident, lor ~ (3) significant1y' reduce.a y
isafety margin, then'that_is a' valid' basis for finding NSHC.
However, in 4
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~that case lyou need to show in-the-notice how the compensatory actions hf result:in a -license amendment that does not significantly increase N,
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< iprobability/ consequences,-does not significantly decrease safety margins-
- a'nd does~not create a new or'different accident.
1 Thus, my objection to the proposed: notice is that a valid
- basis for the l
l proposed MSHC finding has not been provided. cTo remedy this, 1 suggest
- :.that you' mod,1fy -the proposed _ notice:
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(1).'.to 'show in detail-that eurple (vi) of actions likely to
. involve NSHC. applies or
- (2)f t'o show how compensatory measures make this license amendment
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satisfy the NSHC criteria or (3)ltoprovdesome.othervalidbasis,usingeithertheexamplesor
' the NSHC criteria, for finding NSHC here.
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