ML20105C154
| ML20105C154 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Surry |
| Issue date: | 02/22/1984 |
| From: | Gray J NRC |
| To: | Neighbors D NRC |
| Shared Package | |
| ML20102A920 | List:
|
| References | |
| FOIA-84-166 NUDOCS 8502090328 | |
| Download: ML20105C154 (2) | |
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Note to:' Don Neighbors From:
J.' Gray
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SUBJECT:
SURRY AMENDMENT IMPLEMENTING APPENDIX I REQUIREMENTS DELD.has been asked to concur in Surry license amendments incorporating
~ Appendix.I requirements and in the approval of the Offsite Dose Calculation Manual (ODCM) and the Process Control Program (PCP).
I have several-problems with this package.
Although we issued a Federal Register notice relating to these amendments in July 1983, this package would authorize, among other
. things, tech. spec. changes which were only submitted in letters on
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~ January 11'and February 3,1984.
While the January and February changes may not be significant, they were never noticed and no proposed NSHC
-finding as to those amendments was ever published. Thus, the notice requirements for..those particular changes have not been met and those
- changes cannot now be issued.
Secondly, we purport to approve the ODCM and the PCP, although with conditions.
It is not at all clear whether our approval is dependent
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time in' the future or whether that is just something we would like to
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see. happen. -In addition, it is not clear whether our " approval" of the
- 0DCM and PCP involv'es a license amendment or not (that approval is mentioned in;the proposed notice of licensing action).
If a license famendment'is' involved, then at least:the PCP approval was not noticed
.since the PCP was not filed until. November 4, 1983, several months after the Federal Register notice for these amendments.
Finally,'the SER in support:of these amendments contains a NSHC finding zin the.first' full paragraph on p. 4.
If there have been~no: comments on the proposed NSHC finding in the July-Federal Register notice.and there areJno requests for hearing, a NSHC finding at this stage is unnecessary.
In summary:
'(1). All aspects _ of this package ~ were not properly noticed. Those
-' tech. spec. changes which were the subject of licensee's
-~ January.11.and February-3, 1984 supplemental applications should.either be removed from their package or the issuance of
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.all these. tech. spec. changes.should be delayed until January L_
and February 1984 changes are properly noticed and the 30-day notice period for them expires.
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(2) The' status of~the'0DCM and PCP. approval is wholly unclear both
.in. terms'of whether we are unconditionally approving them and in terms'of whether the approval constitutes a license
-~ amendment.
If the_approvalLdoes not constitute a license
- amendment, then it should be separated from this amendment package'and separately provided to.the licensee.
If it does fconstitute a license. amendment, then the PCP portion has not c been properly noticed.
V (3) ~;The-NSHC finding need not be included in the SER unless
' : comments on'the proposed NSHC and/or requests for hearing were
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creceived.'.
.Because-of.the. foregoing problems, we are not prepared to concur in this
_ pa'cka'ge 'at.this time.-
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