ML20205A952

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Discusses Review Re Issue of Draft FSAR Pp Submitted as Part of Rule.Ogc Not in Position to Legally Object to Staff Proposal Not to Require by Rule Submission of Revised Pp Prior to Issuance of Amend
ML20205A952
Person / Time
Issue date: 09/28/1998
From: Mizuno G
NRC
To: Lavie S
NRC
Shared Package
ML20205A488 List:
References
FRN-64FR12117, RULE-PR-21, RULE-PR-50, RULE-PR-54 AG12-1-018, AG12-1-18, NUDOCS 9903310109
Download: ML20205A952 (1)


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,- From: Geary Mizuno To: Steve LaVm

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. Date: 9/28/98 3:38pm

Subject:

Source Term Revision Rulemaking OGC has reviewed the issue of draft FSAR pages being submitted as part of the rule, and we have decided that OGC is not in a position to legally object to the Staff proposal not to require by rule the submission of the revised pages prior to issuance of the amendment. However, OGC will include a note in its "no legal objection" to the rulemaking package that OGC strongly recommends that generic rulemakin0 be undertaken to address the need for submission of proposped revisions to the FSAR pages as part of all license amendments (it is unclear whether this would be done in Section 50.90-92, or elsewhere). i Separately, OGC mangement has directed me to advise the Staff of two additional matters: (1) the Staff needs to consider whether the required license amendments approving the use of a different source term are to be considered involving "no significant hazards consideration," such that the staff may issue the license amendment prior to completion of any hearing (the SOC should address this matter); and (2) the SOC should explicitly state that licensees should be aware that source term changes, when implemented may require technical spdcification changes which must also be obtained through license amendment.

J CC: Janice Moore, Joseph Gray, Lawrence Chandler, S..

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