ML20105C272
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Note to:
Elinor G. Adensam From:
J.R. Gray Re:
McGuire License Amendment Packages for Setpoint on UHI Accumulator Automatic Isolation and for Spent Fuel Transfer
- Between Units The referenced license amendment packages were submitted to OELD review at approximately close-of-business on May 5,1983.
By the time I received the packages, the persons necessary for OELD concurrence were unavailable..Accordingly, these packages were not concurred in by the proper OELD personnel and the license amendments were not issued on
- May 5; As such, these packages must now be revised and processed in accordance with the new regulations for license amendments implemented pursuant to the so-called'"Sholly" amendments to Section 189 of the Atomic Energy Act.
.I'm returning these amendment packages to you for appropriate processing pursuant to the new regulations.
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Note to:
Joe Scinto N./
From:
Mack Cutchin
SUBJECT:
COMMENTS ON PROPOSED TS's AND NSHC DETERMINATION FOR TMI-1 OTSG REPAIR As' we discussed, I am bothered by GPU's proposed revision to the TS's.
The current version of the TS's speaks in terms of plugging limits and of plugging defective tubes to remove them from service, i.e., the steam generator is returned to operable status by removing from service tubes containing defects.
Defects are presently defined as tube imperfections that exceed the plugging limit. 'The proposed version of _ the TS's speaks in terms of repair limits and of repairing or r_emoving from service tubes that contain defects.
Defects are to be defined as tube: imperfections that exceed the repair limit.
In g view the proposed version of the TS's is not clear as to what actions the Licensee can and cannot take without prior NRC approval.
Under the current version of the TS's, the Licensee can plug tubes and return to power without prior NRC approval.
Under the proposed version of..the TS's, it is no longer clear that Licensee can plug tubes and return to power without prior NRC approval.
Nor.is it clear whether NRC approval of the repair method (including " repair" by plugging) is necessary prior to performing the repair.
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- Although I have marked-up the proposed version of the TS's in an attempt to make them clearer, I believe the TS's need more work after the Staff
-indicates the extent of the restrictions it does and does not intend to impose.
As to the Licensee's "NSHC" Determination, Licensee appears to assume that anything approved by the NRC does not involve a significant hazards consideration. Other than the Staff's naked assertion that the Licensee e
has proposed " compensatory measures," there is no indication in any of the papers contained in the concurrence package as to why the Staff.has decided NSHC is involved inIts approval of the return,of TMI-1 to operation with repaired OTSG's.
Even so, although there may be policy reasons such as wanting to see more details in the FR notice or wanting to review the Staff's basis for its NSHC determination before it issues a EFR notice,- if the Staff will modify the FR notice as I have marked it up, I see no legal reason why the FR notice cannot be issued.
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?-4 Note to:
M. Dean Houston From:
Mary E. Wagner
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Subject:
Grand Gulf -- Federa Register Notice of Proposed Amendments I am sending this package back without concurrence, because 1) the proposed amendments are not sufficiently described in the Notice to inform the public as to what the amendments are, and 2) the reasons for the NSHC finding are not given.
With regard to descr.ibing the amendments, those involving typos, nomenclature errors and the like should be listed by tech spec. number and, at a minimum, be collectively described as involving typos, etc.
As for the thirteen amendments requiring safety evaluation, each one should be identified and sufficiently described so that the public will be informed as to what the changes are.
With regard to the NSHC findings, the current Notice as drafted does no more than list the three standards in 10 CFR % 50.92. There needs to be some explanation as to why these standards apply to each of the proposed amendments.
The Commission has provided guidance concerning the appli-cation of these standards by providing certain examples (48 FR 14870).
One of the examples of actions involving NSHC is a purely administrative change to the tech specs, for example, a change to achieve consistency throughout the tech specs, correction of an error, or a change in nomenclature.
For the proposed amendments covered by this example, the reason for the proposed NSHC finding is that these amendments precisely
- fit the Commission's example of an amendment not involving a SHC, and the Notice should so state.
For other proposed amendments, other examples may be applicable and should be cited. When no example is applicable, there must be some discussion as to why the 5 50.92 standards are met.
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In addition, as I briefly mentioned to you on the telephone a couple of days ago, some of 'these proposed amendments may be covered by the original notice of opportunity for hearing on the full power operating license and therefore need not be renoticed again.
Under this theory (still only in the discussion stage and being analyzed within OELD), any amendment that constitutes an action in the chain of events necessary for a full power finding need not be prenoticed, since it is covered by the original notice on the full power license. Under this theory, the kind of amendment to a 5% license that would not need to be prenoticed is the kind that arises because of going to full power, not those amendments that are needed for continued operation at 5% power.
In addition, an amendment to a 5% license that has nothing to do with operating at full power or 5% power, but that is directed at correcting an error, need not be prenoticed since an amendment to correct such an error is covered by the original notice on the full. power operating license.
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g The following is an example of the kind of amendment to a 5% license
- that was not covered by the original notice, and which must be prenoticed under this theory:
a tech spec requires a test that cannot be performed until the unit reaches 75% of rated power.
In order to not be in viola-tion of the tech specs, the tech specs must be amended to provide that the test in _ question does not apply until 75% power is reached.
This is not the kind of an amendment contemplated by the original full power notice and it must be prenoticed.
Possible examples in.this amendment package of the category of amendments which do not require prenoticing are:
March 24 submittal, No.1 (nomenclature correction); No. 2 (typo); No.19 (error unrelated to either 5% or full power).
All of the proposed amendments should be carefully analyzed to ascertain which may fall under the original notice.
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