ML17109A134

Non-Concurrence for Brunswick 5b LAR (NCP-2017-006) Sections a, B, & C

ML17109A134
Person / Time
Site:	Brunswick
Issue date:	04/19/2017
From:	Ed Miller Plant Licensing Branch II
To:	Gideon W R Duke Energy Progress
Hon A L, NRR/DORL/LPL2-2, 415-8480
Shared Package
ML17109A132	List: ML17109A134
References
NCP-2017-006
Download: ML17109A134 (5)

Text

NCP-201 7-0 0 6 Section C As the NCP Approver, I have read and considered the submission from EEEB staff. Prior to discussion of the issues, I would like to acknowledge the work of the EEEB staff and recognize that it is good that they are exercising their ability to register their concerns through the NRC's non-concurrence process.

Summary of Issues

The EEEB staff is objecting to the issuance of the amendment to the Brunswick license to implement TSTF-425 (Risk-Informed Surveillance Frequencies). The EEEB Non

-concurrence has four core objections to the proposed license amendment request (LAR)

1. The proposed amendment would modify the Brunswick Technical Specifications (TSs) in a manner that doesn't meet the current licensing basis of Brunswick and NRC regulatory requirements. Specifically, General Design Criterion (GDC) 17, GDC 18, 10 CFR 50.36(c)(3), and 10 CFR Appendix B Criterion III.

2. The Topical Report (TR) Safety Evaluation (SE) was not reviewed by the Office of the General Coun s e l (OGC). 3. There are no backstops provided for the Surveillance Requirement (SR) frequencies that would be relocated to the licensee controlled document. 4. The proposed amendment is risk

-based, not risk

-informed.

Evaluation of Non

-Concurrence The objections raised in this non

-concurrence are identical to those raised by EEEB staff during the NRC review of a TSTF

-425 LAR for the Perry Nuclear Power Plant, Unit 1 (NCP

-2015-012). The non-concurrence, including the NRC's response to the n on-concurrence is available under Agencywide Documents Access and Management System Accession No. ML16033A197. As no new issues have been raised by the current non

-concurrence, nor has additional technical justification for the issues been provided, I find that the previous resolution of the issues remains valid. Thus, the NRC staff should proceed with issuance of the LAR.