ML20063Q177
| ML20063Q177 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/06/1990 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR18608, RULE-PRM-50-55 55FR18608-00020, 55FR18608-20, ULNRC-2245, NUDOCS 9008210198 | |
| Download: ML20063Q177 (4) | |
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". f ::e W 149 PETITION RULE PRM 50-55 gq v
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O Mr. Samuel J. Chilk, Secretary U..S.
Nuclear Regulatory Commission Attention:
Docketing and Service Branch:
Washington,=D.
C.
20555
Dear Mr. Chilk:
ULNRC-2 24 5 DOCKET No. 50-483
.CALLAWAY PLANT NOTICE OF RECEIPT OF-PETITION FOR RULEMAKING, REVISIONS TO' FINAL SAFETY ANALYSIS REPORTS, 10 j
CFR 50, FEDERAL REGISTER VOL..'55, PAGE 18608-MAY-3, 1990, REQUEST FOR' COMMENTS l
These comments are submitted:by the. Union Electric Co. in response to the request of the U.S.
Nuclear Regulatory Commission (NRC) for comments on a l
petition for rulemaking concerning the frequency of
)
Final Safety Ana3ysis Report (FSAR) revisions under 10 CFR.Part 50 (55~ Fed. Reg. 18608 - MayE3, 1990).
In its petition, Yankee _ Atomic Electric Company seeks a changeLto the current requirements.of'10 CFR 50.71(c)(4) that each licensee submit an annual revision to its FSAR.
The petitioner; requests-that-the regulation be modified to allow' revision submittals within six months following completion ^of a licensee's L
planned refueling outage'.
Union Electric recognizes the E
need for periodic updates of each facility's'FSAR to provide the NRC and the public with. current'information regarding the design features, operating.
I-characteristics, and safety analyses of that; facility, i
We support a change to 10 CFR 50.71(e)(4) because we-J believe that significant benefits will follow'from the adoption of-the; petitioner's request.
s We believe that FSAR revisions should be-driven by circumstances rather than by an arbitrary time-schedule.
Adherence to a prescribed annual revision cycle could force a licensee to submit an FSAR update shortly before the installation of a. major modification.
As a consequence, the subsequent modification would render the FSAR out-of-date almost:immediately.
Allowing FSAR revisions to be linked to the completion l
of refueling outages gives more assurance that an FSAR will contain current information on any significant outage-related changes to the facility it describes.
9008210198 900706 PDR PRM PDR 50-55 DSID
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Mr.'Gamuel J.;Chilk,'Socrotary.
U.E S. Nuclear Regulatory Commission page Two l
Further, because'of the' number and complexity of modifications that may be' accomplished in a refueling outage, we-_suggest that the FSAR revision be submitted within nino months following an outage as opposed to the six months requested by the petitioners.- This is a more reasonable'timo period in which to prepare FSAR updatos.
Accordingly, the following" revised wording to 10 CFR 50.71(c)(4) is suggested:
Subsequent revisions shall be submitted no less frequently than nine months following the
. completion of a planned refueling outage and shall reflect'all changes up to a maximum of six months prior to the date of filing.
If two or more facilities. share a common FSAR and the licensee elects to revise that FSAR
'following refueling outages, the licensee shall~ designate the refueling outage schedule i
of one of the facilitics to establish the schedule for revisions of thc common FSAR.
i Union Electric support, the petitioner's position that the requested chango (as revised) to 50.71 would be beneficial.to-both the<NRC and the-industry.
The resulting. longer interval-between FSAR updates would benefit'many licenoees by reducing the administrative costs associatedLwith preparation _of; those updates.
NRC staff time for FSAR reviews would be similarly reduced and fewer licensee requests for.
schedulo-related exemptions would be generated.
We believe that these benefits can be' achieved:with no adverse effect on-the health and safety of the public.
We appreciate the opportunity to7 comment on i
this issue and would be pleased to discuss our comments further with the appropriate NRC personnel.
Very truly yours, Donald F. Schnell JMC/sla
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cc:
Gerald Charnoff,-Esq. _
Shaw, Pittman, Potts & Trowbridge 2300 N.
- Street, N.W.
i Washington, D.C.
20037-Dr.
J. O. Cermak j
CFA, Inc.
4 Professional Drive (Suite 110)
Gaithersburg, MD 20879 R; C.
Knop Chief, Reactor Project Branch 1
-U.S.
Nuclear Regulatory' Commission j
Region III 799-Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Bartlett-Callaway Resident Office U.S.
Nuclear Regulatory Commission d
RR#1 l
Steedman, Missouri 65077 j ;
Anthony T.
Gody, Jr-(2)
Office of Nuclear Feactor Regulation
-i U.S, Nuclear Regulatory CommissionL 1 White Flint, Nortl, Mail Stop 13E21 11555 Rockville Pike Rockville, MD 20852 Manager, Electric Department Missouri Public Service Commission P.O.
Box 360 Jefferson City, MO 65102 i
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/QA Record (CA-758)
Nuclear Date E210.01
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DFS/ Chrono D.
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Schnell J. E.
Birk J. V.
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Stiller G.
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Randolph R.-J.
Irwin-H. Wuertenbaecher
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