ML20105C257

Provides Results of Review of NSHC Package Re Fire Protection Amends.Lists Problems W/Proposed Basis for NSHC Finding.Concurrence Not Recommended for Notice in Present Form

ML20105C257
Person / Time
Site:	05000000, Crane
Issue date:	03/15/1984
From:	Gray J NRC
To:	Silver H NRC
Shared Package
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References
FOIA-84-166 NUDOCS 8502090356
Download: ML20105C257 (2)

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Note to:

H. Silver From:

J. Gray

SUBJECT:

' P,R0 POSED NOTICE OF FIRE PROTECTION AMENDMENTS FOR TMI-1 OEl.D has been asked to concur in a proposed notice for fire protection license. amendments for TMI-1. The amendment would:

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,(1) ~ add f' ire protection equipment to the list of equipment requiring surveillance;

. (2). add administrative controls'on the fire detection and suppression system; (3) ~ revise surveillance _ requirements on_the Co system in the p

~ cable spreading room to conform to system capabilities

-(4) revise surveillance requirements on fire suppression systems in the-air intake tunnel to eliminate deluge system operability when halon systems are inoperable.

!There are some problems with the proposed' basis for the NSHC finding on several of these changes.

Asla. basis' forifinding NSHC for item (2), the notice indicates that example (vi) of-examples of actions not likely to involve SHC applies.

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Example (vi)1 s a change that may increase the probability / consequences i

of an accident or reduce' a safety margin but the results of the change care within acceptable criteria in the Standard Review Plan (SRP).

You attempt to show that example. (vi) is applicable to item (2) by' noting

-that the SRP indicates'that use.of the. Standard Technical Specifications is-

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acceptable and' indicating that item (2) would modify administrative

-controls to conform _to the Standard Technical Specifications.

I believe

!that this approach really stretches things to make item (2) fit example (vi). The fact that-the SRP says that use of the Standard Technical

Specifications-is' acceptable does not mean that the-Standard Tech.

Specs. constitute " acceptable criteria in the Standard Review Plan."

If

they did, then any license change conforming Tech. Specs. to the

_ Standard Techk Specs. would always fall within example (vi) (and thus c

involve NSHC), even if the license change otherwise significantly reduces a safety margin, significantly increa'ses the probability / consequences of;an accident or' creates a new accident.

In fact, es the' notice-

- describes item (2) (adds administrative controls), it appears that item (2)iis a change imposing new restrictions.' If that is the~ case, then litem (2) falls.under Commission example (ii) of actionsi not likely to

-involve:SHC and that should be the basis for' finding NSHC.

If that is c.p h-8502090356 840518 s

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not the case,-then you need to show how the item (2) changes do not significantly increase the probability / consequences of accidents, significantly decrease a safetu margin, or create a new accident.

While you~ give some reasons why the changes in items (3) and (4) are acceptable, there is no clear relationship between those reasons and the

- conclusory assertion that "[t]herefore, Changes 3 and 4 above would not"

- significantly _ increase the probability / consequences of an accident, create a new accident or significantly reduce a safety margin.

I

- believe that to provide an adequate basis for a NSHC finding for items

(3) and (4), you must specifically, for each of those items, show how the NSHC. criteria of 10 CFR % 50.92 are met.

For example, for item (4),

- show how elimination of the requirement of deluge system operability when the halon system is inoperable will neither increase the probability of.an accident nor significantly increase the consequences

- of an accident (fire), will not create the possibility of a new

- accident, and will~ not significantly reduce existing margins of safety.

- Because.of the problems noted above in the bases for the NSHC finding for the license changes represented by items (2), (3) and (4), I am not prepared to concur in the -notice as presently constituted.

10.PJ Gr y I

cc: J.'Scinto J. Goldberg R. Rawson-e i

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