ML20105D287

Provides Results of Review of NSHC Package Re Amend on Control Element Assembly Position Indication.Suggests Bases for Proposed NSHC Finding Be Modified

ML20105D287
Person / Time
Site:	05000000, Calvert Cliffs
Issue date:	05/18/1984
From:	Gray J NRC
To:	Jaffe D NRC
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FOIA-84-166 NUDOCS 8502090642
Download: ML20105D287 (1)

Text

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I Note toi: Dave Jaffe From:.

.J. Gray

.SUBJECTi : NOTICE ON PROPOSED CALVERT CLIFFS AMENDMENT ON CEA POSITION INDICATION

~ 0 ELD has been asked to concur in a notice of a proposed Calvert Cliffs

' amendment which would expand the allowed use of electrical limit switches to. provide position indications for the CEAs.

I have a problem with the

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stated basis for the proposed NSHC determination.

In the notice you propose to find NSHC on the ground that this amendment Jis >similar to the Connission's example of a " purely administrative

- change not likely to involve SHC.

You go on to indicate that this amendment is similar to the " administrative change" example because it c

would achieve consistency between the current stated basis for the rod position indication Tech. Specs and the Tech. Spec. requirements.

That is a novel argument but not one which is sufficient to establish that the Comission's _" administrative change" example applies here.

While it is true that the " administrative change" example encompasses amendments to, for example, correct typographical errors or achieve consistency in nomenclature in the license, the proposed changes'here are not of that type.

First of all, the statements of bases for tech, specs, are. themselves, not legally binding requirements.

The Comission, I believe, could not have contemplated that the " administrative change" example would encompass substantive changes to legally binding requirements

.in the tech specs, simply to make the tech. specs, consistent with the non-binding bases. More importantly, an amendment expanding (our characterization in the notice) the permitted use of limit switches for rod position indication beyond that now permitted by the license really appears to be a substantive change with safety significance ~and not just

a. purely administrative change involving correction of typographical-errors, non-substantive changes in nomenclature and the like.

In short, L

the " administrative change" example does not appear to apply here.

I' I suggest that you modify the bases for the proposed NSHC finding either by finding an applicable example of an action not likely to involve SHC or by addressing the criteria for NSHC in 10 CFR l 50.92.

I cannot concur in the proposed notice in its present form.

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PDM ADAToh4166

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