ML20105C241
| ML20105C241 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Peach Bottom |
| Issue date: | 03/05/1984 |
| From: | Gray J NRC |
| To: | Gears G NRC |
| Shared Package | |
| ML20102A920 | List:
|
| References | |
| FOIA-84-166 NUDOCS 8502090351 | |
| Download: ML20105C241 (1) | |
Text
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[ Note to:
G. Gears From:
- J'. - Gray.
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SU5 JECT:T. PEACH BOTTOM AMENDMENT CHANGING LC0 ACTION STATEMENT FOR 1 REACTOR WATER CLEANUP (RWCU) SYSTEM 0 ELD has.been asked to concur in a notice and proposed NSHC finding for
- certain license.amendmentsLfor Peach Bottom.
While the notice and Lstated bases for the NSHC findings for most of the changes appear to be s
- adequate,1
- have problems. with.the bas'is for the NSHC finding for the 1
.That c ange would relax an LC0 on the h
change involving :the. RWCU. System.
11noperability of a high temperature instrument switch.
The problems I have-with the basis you propose for finding NSHC is that you?have not provided an affirmative basis for NSHC (either by showing Lthat one of;the Commission's examples of an action involving NSHC Japplies or by, showing.that the change does not significantly increase-LtheTprobability or consequences of an accident, does not~ create a new accident, and doesinot.significantly. reduce a safety margin).
- Rather, x:
.you show;that one of'the examples ~ of actions' that would involve
- significant. hazards.considerationsimay not apply.
That is not good 1
enough. =We. mustmakeL an affirmative showing that the: change involves no 1significant' hazards considerations.
Because I'believe that, for the RWCU change, we have not provided an-Jadequate' basis for:the proposed NSHC-finding, I am not prepared'to iconcur in zthe notice.astpresently constituted.
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m March 9, 1984 Note to:
G. Dick From:
J. Gray
SUBJECT:
FUEL CHANGE AMENDMFNT FOR GINNA
-0 ELD has been asked to concur in a proposed notice and proposed no significant hazards consideration finding (NSHC) for an amendment to the Ginna license which would authorize the use of a new and different kind o_f fuel and modify various technical specifications to accommodate the
.new fu'el.
I don't believe that there 'is adequate support or basis for the proposed NSHC finding.
Rather than show-i that one of the Commission's examples of actions not likely to involve SHC applies to the amendment, it is stated that
.NSHC is involved'because.the amendment will not significantly increase the probabili.ty or _ consequences-of accidents, significantly decrease a safety margin or create.a new accident.
While statements are made on pages 2 and 3 of the proposed notice about how the new fuel and core was analyzed and how Westinghouse. criteria are satisfied, there is no apparent relationship between these various statements and the criteria for finding HSHC.
I_believe that you must show how each proposed change v
to the technical specifications meets the NSHC criteria.
For example,
.. demonstrate that the positive moderator temperature coefficient which these changes would authorize would not result in a significant increase in the consequences of accident and would not create the possibility of
..a new accident not previously considered.
The _present notice does not provide a rational basis for concluding that the proposed amendmer t involves NSHC. Because of that, I am not prepared to concur in it.
.R Gra
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