ML17109A134
| 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: |
| 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.