NG-90-1446, Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements

Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements

ML20055F438
Person / Time
Site:	Duane Arnold
Issue date:	07/02/1990
From:	Mineck D IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-55FR18608, RULE-PRM-50-55 55FR18608-00025, 55FR18608-25, NG-90-1446, NUDOCS 9007170039
Download: ML20055F438 (2)

Text

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- DOCKET NUMBER PETITION RULE ?RM S-f5 j

(65M /84 M) 00LKE1ED USNRC lowa Electric Light and Power Company July 2,1990 '90 JL 10 AB:34 NG-90-1446 I

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Mr. Samuel J. Chilk, Secretary Office of the Secretary of the Commission- j U.S. Nuclear Regulatory Commission Attention: Docketing Services Branch ,

Washington, DC- 20555

Subject:

Duane Arnold Energy Center  !

Docket No: 50-331 l Op. License No: DPR-49 l Comments on Petition for Rulemaking Regarding Final Safety Analysis. Report Revisions ,

References:

(1) 55 Federal Register 18608 dated May 3,1990 (2) Letter from J. F. Colvin (NUMARC) to S. J.

Chilk (NRC) dated July 2,1990 ,

.1 File: A-ll6, A-119 I

Dear Mr. Chilk:

s In Reference 1,. the Nuclear Regulatory Commission published notice of- receipt of a petition for rulemaking filed by the Yankee Atomic Electric Company regarding 1

the schedule for submittals of revision to the Final Safety Analysis Reports (FSARs). In'its petition, Yankee Atomic requested that the NRC amend

~10CFR50.71(e)(4) to change the requirement that nuclear power plant licensees file revisions to their FSARs no' less frequently than annually. The proposed alternative would require FSAR revisions to be filed within six months after the completion of a planned refueling' outage. This' letter responds to the=NRC's request for comments on the petition for rulemaking.

, The Nuclear Management and Resources Council (NUMARC) submitted their' comments 1 on the petition for rulemaking (Reference 2) supporting the Yankee Atomic peti-

~

tion. NUMARC concluded that the proposed alternative requirements would benefit

.the. industry by reducing administrative costs associated with preparation of FSAR revisions, reducing-the administrative burden on the NRC staff and enhan-cing the quality and accuracy of information contained in a licensee's FSAR. We fully endorse'these comments.

We recognize the benefits of periodically revising our FSAR. Hwever, requiring l- submittal of revisions within six months following completion of a planned l- refueling outage instead of annually would allow for more timely updating of the n information contained in our FSAR. For example, major plant modifications 9007170039 900702

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Mr. Samuel J. Chilk July 2,--1990 NG-90-1446 .

Page Two 1 are normally installed during planned refueling outages and accident analyses I are changed as a result of new fuel reloads. These changes could result in our FSAR being outdated for more than one year under the present requirements, l whereas under the proposed alternative schedule, our FSAR would be updated to i reflect these changes within six months. This proposed change would result in an estimated savings.of $500,000 over the remaining life of the. plant. We also l believe the proposed alternative would reduce our administrative burden as well 1 as that of the NRC staff without compromising the health and safety of the -l public. l We appreciate the opportunity to comment on this petition for rulemaking and i would be pleased to-further discuss our comments with you.

Very truly yours, j 1

Daniel L. Mineck Manager,' Nuclear Division DLM/NKP:DMB*

- cc: N..Peterson L. Liu ,

L. Root t R. McGaughy '

Commitment Control No. 900159 J