ML20105D258

Provides Results of Review of NSHC Package Re Core Spray Sparger Amend.Ser Undercuts Basis for Proposed NSHC Finding

ML20105D258
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 8502090632
Download: ML20105D258 (1)

Text

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v ci e en December 14, 1983 Note to:

J. Lombardo

from:

'J. Gray

SUBJECT:

0YSTER 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

. tor 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 says.that we cannot assign any reliability to crack length measurements on which any deferrallof 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 that we don't know whether cracks are progressing and the sparger is

. degrading or not.

I see no justification for allowing further deferral

~of sparger-replacement.

Without a substantially more convincing story-on 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 cestablishes-that past inspection indications are unreliable.. What-purpose would be served in comparing future inspection results to past inspections.in which we have no confidence).

.R.

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