ML20055F425
| ML20055F425 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/02/1990 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR18608, RULE-PRM-50-55 55FR18608-00023, 55FR18608-23, NUDOCS 9007170012 | |
| Download: ML20055F425 (2) | |
Text
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Duquesne L@t Company 6"e,sleF*d 5mpengport, PA 15077 4)04
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. Secretary of:the Commission U.
S. fuclear Regulatory Commission LAttn:
Docketing and Service Branch Washington, DC~'20555-4
Reference:
Notice of Receipt of Petition for Rulemaking Yankee Atomic Electric Company,-
Docket No. PRM-50-55, 55FR18608 Gentlemen:
These commentsi are submitted by Duquesne Light Company (DLC) in. response to'a request by the U.S.
Nuclear Regulatory Commission (NRC) for comments.on
- a. petition for rulemaking filed by the
. Yankee Atomic Electric Company.
The notice of receipt of petition
-for 1 rulemaking= was published in the Federal Reaister on May 3, 1990'(55FR18608).
The' petitioner requests that the NRC change the requirement that nuclear power plant licensees file revisions to the. final.
safety. analysis report (FSAR) no less frequently than annually.
~The petitioner also' requests that7 the regulations' require that
? revisions. be: filed.no later than six months after completion of
)
each.= planned refueling outage for a
licensee's facility.
The.
-petitioner believes this change would permit more effective use of p
' licensees and NRC resources and allow more meaningful scheduling L
-for FSAR updates.
l
- DLC' believes that' the petitioner's. suggested schedule.for updating' the-FSAR would be only marginally advantageous.: Certain l,
costs are-incurred regardless of the timetable used in submitting l.
FSAR.: updates..
- Also, the NRC would expend an equal amount of l'
' resources-reviewing the FSAR amendments:for any revision frequency-because the technical content will be unchanged.
s Ii i
The petition would give the Executive Director for Operations
, ( EDO) - authority-to impose a specific submittal date on a licensee, s
but does not-appear-to. impose any guidelines for exercising this authority.
10CFR50. 54 (f) gives the EDO-authority to request'a-L flicensee to submit important information and also specifies L
cguidelines to follow when considering such'a request.
Therefore, l
if. adopted, the
- phrase, "unless directed otherwise by the EDO" should 'be deleted in favor of a reference to 10CFR50.54 (f).
i I-9007170012 900720 W l
1;
l-
~ Notics of'Racolpt of P3tition_for Rulcmaking -
t
- Yankee Atomic Electric Company,
- Docket No. PRM-50-55, 55FRIB608 Page 2 The petitioner believes' that major modifications performed during refiteling outages give rise to the most extensive and
- meaningful changes to the FSAR.
DLC believes that program
- changes, organizational
- changes, and changes to analyses can be equally _ extensive and meaningful from a regulatory standpoint.
Increased timeliness of raporting significant plant modifications may be offset by a decrease in the timeliness of reporting other types of changes.-
The' petitioner states that many of the costs of producing a FShR revision 'are independent of the size or content of the revision.
The costs of distribution, controlled copy
- accountability, preparation of insertion instructions, and changes to Tables of Contents are examples of costs that are not affected b);
the size of a
revision.
However, the costs of preparation, reviewing, word processing and printing associated with specific changes are not independent of the size of a revision and these costs contribute more to the total cost of publishing a FSAR update.
The latter costs would be incurred regardless of how often the FSAR is revised.
Since it is suggested that administrative burden on the NRC L
would be reduced, the NRC should consider whether costs associated with administrative processing of an amendment (i.e. receiving, distribution,- etc.)
are significant-when compared to costs of reviewing the technical content of the amendment.
Review = costs
.would be unchanged because the technical content of.the FSAR amendment. will be the same regardless of how often the FSAR is revised.
If implemented, the rule should allow a licensee the choice of continuing withL the current method of submittal.
It has, in the
- past, been sufficient to satisfy regulatory needs and no new regulatory concerns in this area are in evidence.
Thank you for the opportunity to comment on this issue.
DLC looks forward to working with the NRC -on future regulatory changes.
Very truly yours, dib D. Sieber Vice President Nuclear Group
-