ML18089A621

March 20, 2018, Presentation Slides - Treatment of Change Control for the Surveillance Frequency Control Program (SFCP)

ML18089A621
Person / Time
Site:	Nuclear Energy Institute
Issue date:	03/30/2018
From:	Nuclear Energy Institute
To:	Purnell B A Plant Licensing Branch III
Purnell B A, NRC/NRR/DORL/LPLIII, 415-13
References
Download: ML18089A621 (13)

Text

"To reduce duplication of effort, 10 CFR 50.59(c)(4) specifically excludes from the scope of 10 CFR 50.59 changes to the facility or procedures that are controlled by other more specific requirements and criteria established by regulation." "Activities controlled and implemented under other regulations may require related information in the UFSAR to be updated. To the extent the UFSAR changes are directly related to the activity implemented via another regulation, applying 10 CFR 50.59 is not required." "UFSAR changes should be identified to the NRC as part of the required UFSAR update, per 10 CFR 50.71(e)."

"Evaluating changes to the NRC commitments is a separate activity based on a method acceptable to the NRC for managing and changing regulatory commitments, e.g., NEI 99-04.""- using a method acceptable to the NRC - (e.g., NEI 99-04)"

"The major distinction between obligations and other parts of the licensing bases is that changes generally cannot be made without prior NRC approval.""The change control mechanisms and reporting requirements are defined by regulations such as 10 CFR 50.59, 50.54, and 50.71.""Regulatory commitments are appropriate for matters that are of significant interest to the staff but do not warrant - inclusion in updated final safety analysis reports (UFSARs) or programs subject to a formal regulatory change control mechanism."

"Many of the commitments for license renewal are no longer commitments since they are subsequently incorporated into the plant's UFSAR-"

conforming changes with these conforming changes