ML20105B855

Provides Results of Review of NSHC Package.Agrees W/ C Woodhead Note Re Spray Sparger Amend.Amend Should Be Renoticed Providing Another Basis for NSHC Finding or Renotice Giving Prior Opportunity for Hearing

ML20105B855
Person / Time
Site:	05000000, Oyster Creek
Issue date:	12/14/1983
From:	Gray J NRC
To:	Lombardo J NRC
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References
FOIA-84-166 NUDOCS 8502090260
Download: ML20105B855 (1)

Text

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a_

s.,

December 14, 198S T

Note to:

J. Lombardo Fran:-

J. Gray SUBJECTi OYSTER CREEK CORE SPRAY SPARGER AMENDMENT I agree with Colleen Woodhead's note to you to the effect that your SER wholly undercuts the basis for the proposed NSHC finding set out in your

. prior Federal. Register notice of proposed action.

Because of this, I believe you must either renotice this amendment providing another basis (for the NSHC finding or, if.you have no other basis, renotice giving a prior opportunity-for. hearing (as Colleen's note suggests) becauses you cannot make the NSHC-finding.

I have an additional problem, however. This license change would modify

.the present license ~ condition, which requires sparger replacement before any further' operation, to allow operation without sparger replacement for the next fuel cycle, and operation beyond the next fuel cycle contingent upon some undefined " acceptable" inspections.

However, 60%

of the SER discusses how unreliable past inspections have been and essentially establishes that we have no basis today for determining that

' operation with the existing spargers would be safe. The SER actually zsays that we cannot assign any reliability to crack length measurements on which' any deferral of sparger replacement could be based.

In contrast there is only_ one SER paragraph on why it is acceptable to operate without ;sparger replacement and that is rather vague and wholly

> unconvincing in view of the rest of the SER which clearly establishes Jthat we don't know whether cracks are progressing and the Lsparger is degrad?r.g or not.- I see no justification for allowing further deferral of spargerl replacement.' - Without a substantially more convincing story-f ton the adequacy of the existing'sparger for another cycle of operation,

.I don't believe that you'can issue this amendment.- (As an aside, your expectation that future inspections will allow meaningful comparisons

-with past inspection < indications-is not very useful.

This-SER fairly

~

Lestablishes that past inspection indications are unreliable.

What

' purpose would be served'in. comparing future inspection results to past zinspections sin wnich we-have no confidence).

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J.R. Gray 4 3502090260 840518 fp-d PDR FOIA

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PDR

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