ML20105D281

Provides Results of Review of NSHC Package Re Spent Fuel Pit Capacity Expansion.R Rawson Finds Notice Adequate

ML20105D281
Person / Time
Site:	05000000, Oconee
Issue date:	05/18/1984
From:	Gray J NRC
To:	Suermann J NRC
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References
FOIA-84-166 NUDOCS 8502090638
Download: ML20105D281 (1)

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Note to:.. John Suermann From:

J. R.. Gray -

SUBJECT:

PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATION FINDING FOR OCONEE-3 SFP CAPACITY EXPANSION

' 0Et.D has been asked to concur in the proposed notice and NSHC finding for a. license amendment on expansion of the storage capacity for the SFP at Oconee-3.- R. Rawson has concurred in the notice on the basis that it provides an adequate description of the proposed amendment, an adequate descritpion of the basis on which the Staff proposes to make a NSHC

-finding, and an adequate description of what must be done to request a hearing.

=

'Our review, however, was not a review for. the substantive adequacy of the basis for the proposed NSHC finding and our concurrence is not

' concurrence in the substantive adequacy of that basis.

I do-note that I am not aware that we have ever based a finding of no significant hazards consideration on the fact that a license amendment similar or identical to the one in question was previously reviewed and approved for another plant.. In fact, a petition for ruleniaking that would have established

as one basis for finding NSHC that a similar amendment had previously

been approved for another. facility was specifically. rejected by the

~ Commission.. While the proposed NSHC finding for the Oconee-3 SFP amendment:is not entirely grounded upon the fact that a similar amendment was previously approved for Oconee-1/2,'there is an element of that in the basis provided in this notice.

I only want to caution you that the mere fact that:a similar amendment was previously approved for

- Oconee-1/2 may-not necessarily, standing alone, justify a NSHC finding for Oconee-3.

Rather, other facts establishing that the amendment does

notL(1)l involve-a significant increase in the probability'or consequences of accidents previously cons-idered or (2) create the possibility of a new or different kind of accident from any previously evaluated or, (3) involve a significant reduction in a safety margin

~(10 CFR J 50.92) should show that NSHC is involved. As reflected in the Eproposed notice, licensee has presented a detailed analysis arguably x

indicating this,to be' the case. lThis is simply to forewarn you that,.

1should,there be a request for hearing, the final NSHC finding that must 4

be made must concentrate ~on the criteria of '10 CFR 50.92, rather than

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'being limited to arguments 'that similar reracks were approved for Oconee-1/2. A solid, detailed and correct analysis.will be required in L

-view of the questions that have been raised generically over whether SFP

.reracking amendments involve significant hazards considerations.

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