ML20217E223
| ML20217E223 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 09/03/1997 |
| From: | Lochbaum D UNION OF CONCERNED SCIENTISTS |
| To: | Stolz J NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20217E227 | List: |
| References | |
| NUDOCS 9710060394 | |
| Download: ML20217E223 (2) | |
Text
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UNION OF CONCERNED SCIENTISTS September 3,1997 hir. John F. Stolz Director, Project Directorate 12 Office of Nuclear Rcactor Regulation U. S. Nu:! car Regulatory Commission Washington, DC 20555
SUBJECT:
INAPPROPRIATE Ah1ENDh1ENT REQUEST, SALEh! GENERATING STATION UNIT 2
Dear hir. Stolz:
By letter dated August 21,1997, hir. Leonard N. Olshan of your stafT notified the licensee for the Salem Generating Station regarding the public notice for a proposed amendment to the facility operating license.
As indicated in this letter, the Salem licensee had requested the amendment request on an exigent basis by letter dated August 19,1997.
UCS resiewed the stafrs determination with respect to the issue of no significant hazards consideration.
We concur with the staff's assessment that the proposed changes will not adversely affect safety margins at Salem. Ilowever, we strongly disagree with the staffs determination that "the licensee has provided adequate justification for the staff to process this amendment in an exigent manner, as provided in 10 CFR 50,91(a)(6)." he facts do not support such a conclusion.
I spoke with hir, Olshan by telephone on two occasions yesterday regarding this amendment request. hir.
Olshan informed me that the licensee's August 20,1997, fol'owup letter was in response to the staffs reluctance to consider this amendment request as qualifying for exigent handling. hir. Olshan indicated that 1
several other licensees had sought, and had been gracted, comparable Technical Specification changes. hir.
Olshan had no idea if these other licensees had obtained the changes on an exigent basis. hir. Olshan informed me that Salem Unit 2 restarted and did not re-experience the problems, which prompted the l
O expedited amendment request.
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I asked hir. Olshan about a recent similar event at Sequoyah Unit I (see LER 50-327/96011 submitted by Rn letter dated December lis, if 96) in which TVA encountered the same problem as experienced at Salem, but N
handled it via dilution and control rod insertion. TVA indicated that they would submit a license 7
amendment request, presumably under the normal process, to remedy the very problem that this Salem of license amendment request addresses, s<
O lt is troubling that the NRC staff would move so swillly down the exigent pathway simply because this R$
licensee requested it. From my discussions with hit. Olshan, it is not apparent that the NRC tr.iewed prior 0*Z events such as the one at Sequoyah to determine whether the Salem licensee truly had no optica other than this " emergency" Technical Specification relief. Salem Ur.it 2 received its full power operating license in h1ay 1981. If memory serves me correctly, the plant has started up more than once since 1981 gising this licensee amply opportunity to identify overly restrictive Technical Specifications. The fact that this Washington Office: 1616 P Street NW Suite 310
- Washington, DC 200361495
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September 3,1997 Page 2 of 2
" emergency" request was supported by a previously prepared a ' issued Westinghouse safety analysis (WCAP 14672) suggests that this problem has been around for i ne time and did not develop in the past few days. Clearly, this licensee had sufficient opportunity to be cognizant of this potential problem and its ready fix. %at this licensee neglected the opportunity and was " surprised" by the problem during a startup is simply not proper grounds for the NRC to consider this " emergency" license amendment under exigent proccasing.
Despite our considered opinion tut the NRC staffis being inappropriately accommodating to the Salem licensee with respect to this license amendment, UCS will not intervene in this matter. He technical justification for the proposed changes is solid and safety margins at the facility will not be compromised if these changes are approved. Therefore, we see no reason to oppose this amendment even though it is being pursued through improper administrative methods.
I We respectfully ask that the NRC staff seriously review the process under which license amendment requests are processed under exigent conditions. He process appears fundamentally flawed in that it does not, or at least it did not in this case, determine whether the licensee has options other than the requested Technical Specification relief. The availability of other options could climinate the need for exigent handling. In addition, the process does not, or at least it did not in this case, review previous staff actions on comparable Technical Specification changes. The routine handling of similar amendment requests could eliminate thejustification for exigent treatment. Basically, the process appears to rely almost exclusively on information provided by the licensee in support of the amendment request. One of the primary lessons teamed from the hiaine Yankee RELAP5 code issue was that the NRC staff should not rely solely on licensees but should conduct independent verifications. Proper independent verification demands more than merely reading the material submitted by the licensee and reformatting it in a no significant hazards consideration statement.
If there are any questions or comments, please do not hesitate te contact me.
Sinceresy, o dro 1
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O c.v.
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GL Ll C
1 David A. Lochbaum t
h ^. ( 3 b-k se. D M Nuclear Safety Engineer
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cc:
Chairman Shirley A. Jackson
{ g@1 h hir. Samuel J. Collins hir Hubert Bell Senator Joseph R. Biden l
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