ML20205A702
| ML20205A702 | |
| Person / Time | |
|---|---|
| Issue date: | 10/30/1998 |
| From: | Bergman T NRC |
| To: | Frank Akstulewicz, Lavie S, Matthews D NRC |
| Shared Package | |
| ML20205A488 | List: |
| References | |
| FRN-64FR12117, RULE-PR-21, RULE-PR-50, RULE-PR-54 AG12-1-015, AG12-1-15, NUDOCS 9903310050 | |
| Download: ML20205A702 (1) | |
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From: Thomas Bergman To: WNP4.DBM, FMA, OWFN_DO.owf5_po.GSM, SFL
, Date: 10/30/98 8:24am
Subject:
Re: Revised Source Term Proposed Rule Coordination -Forwarded -Reply Sorry this is leng ...
I spoke with Geary yesterday aftemoon, and believe I better understand his position, one part of which I agree with.
l Geary has two positions:
l l 1. Rules should clearly state the extent to which the licensee is required to describe the effects of the rule in the UFSAR (or other change control process if the staff doesn't want to rely on 50.59).
The need to do this is rule dependent. If we desire to control certain aspects of the licensee's approach (say methodologies related to source term) under 50.59, then we need to make sure its explicitly required for the methodologies to be des?ribed in the UFSAR. In the case of source term, if past practice indicates successful description in UFSAR, we may be okay, but this rulemaking does present an opportunity to tighten it up.
Another example, and one rm more familiar with, is the maintenance rule. There is nothing in the MR that would cause it to be described in the UFSAR and hence, it isn't. Had the staff wanted some type of programmatic description, we would have needed to put an explicit requirement in the rule (a discussion of the expectations in SOC may suffice). But in the case of the MR, no need to describe in the UFSAR.
Another example that better highlights Geary's concem (I think) would be the station blackout rule. Nothing in that rulemaking (as far as I know) said to put a description of your coping analyses in the UFSAR. Therefore, if a licensee determined that no changes were necessary,31.g(( physically or to analytical methods (the plant met the coping requirement as designed), then the licensee would have good grounds for not making any modification to the ;
- . UFSAR since the new rule had "no effect" on the facility (note, under staffs proposed interpretation of design basis, j the SBO rule would have added design bases and thus need to be addressed). Now in most cases, licensees had to modify their facilities as a result of the SBO rule, and so the UFSAR would reflect these mods and the bases for them.
l So I think the bottom line of Geary's proposal here is that jLit is important that the licensee's approach to a new I requirement be addressed in the UFSAR, then the best approach is to be explicitly clear in the rulemaking about l what needs to go into the UFSAR. I tend to agree with Geary on this.
- 2. Geary's second issue appears to be that licensee's should submit UFSAR change pages along with license
, amendment requests. The basis for this position is that facility changes have crossed some regulatory threshold ,
l (like being a USQ) and thus the UFSAR changes should be scrutinized more carefully as well.
, While there is merit to this approach, i do not recommend it be implemented for the following reasons: ,
I
- a. The update rulemaking explicitly stated that the NRC would not conduct licensing type reviews on the updates to the UFSAR. While the staff would only be reviewing a small portion of the updated pages (given <20 amends / year and about 200 50.59s per year, per plant), this would still be contrary to original intent of the rule. Second, if a licensee had a technically adequate amendment request, but ' unacceptable' UFSAR changes, would this be an appropriate basis for denial?
- b. In many cases license amendments can be approved withcJt even looking at the UFSAR, it depends on the quality of the submittal. The staff has managed to approve license amendments for 30 years without seeing revised UFSAR pages in advanu, why do we now need this 'essentiar information? Unless we can demonstrate that the staff has erred in making licensing decisions as a result of not having the revised UFSAR pages I can't see a good basis for requesting them at this time. ,
- c. The staffs review should focus on the change to the facliity, not the change to UFSAR. Licensee's don't i (shouldn't) modify the UFSAR, then modify the facility. The modification to the facility drives the change to the UFSAR. Although I agree reviewing UFSAR changes along with the amendment is an additional opportunity to ;
- ensure the licensee properly will comply with 50.71(e), traditionally ccmpliance with 50.71(e) would be addressed through l&E, and I believe that continues to be the best approach, and should not become part of a licensing-type
. review.
CC: emm, simi l
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21 64FR12117 PDR I
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