ML16141A025

Susquehanna Steam Electric Station - Non-Concurrence for Susquehanna TSTF-425 LAR (NCP-2016-005) Sections a, B, and C

ML16141A025
Person / Time
Site:	Susquehanna
Issue date:	05/05/2016
From:	Miller G E Plant Licensing Branch II
To:	Susquehanna
Miller, G. E. LPLII-1
References
CAC MF5151, CAC MF5152, NCP-2016-005, TSTF-425
Download: ML16141A025 (13)

Text

NCP-2016-005 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 amendments to the Susquehanna Steam Electric Station, Units 1 and 2 licenses 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 Susquehanna Technical Specifications (TSs) in a manner that doesn't meet the current licensing basis of Susquehanna 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 Counsel (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 non-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.