ML17348A405

Comment Supporting NUMARC Position on Revised Wording of Petition for Rulemaking PRM-50-55 Concerning Fsars.Resulting Longer Interval Between FSAR Updates Would Benefit Many Licensees

ML17348A405
Person / Time
Site:	Turkey Point
Issue date:	06/29/1990
From:	Bohlke W FLORIDA POWER & LIGHT CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-55FR18608, RULE-PRM-50-55 55FR18608-00012, 55FR18608-12, L-90-241, NUDOCS 9007180080
Download: ML17348A405 (8)

Text

REGULARLY INFORMATION DISTRISUTISYSTEM (RIDE)

A'CCESSION NBR:9007180080 DOC.DATE: 90/06/29 NOTARIZED: NO DOCKET FACIL:50-250. Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION BOHLKEFW.H. Florida Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION CHILKFS.J. Of fice of the Secretary of the Commission

SUBJECT:

Comment supporting petition for rulemaking PRM-50-55 re revs to FSAR,10CFR50.

DISTRIBUTION CODE: DSlOD COPIES RECEIVED:LTR t ENCL ~ S1ZE:

TITLE: SECY/DSB Dist: Public Comment on Proposed Rule (PR)-10CFR NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL: ADM/FIPS/RPB 1 1 NMSS/IMOB 1 1 G D - M18 1 1 OGC/SAIP15-B-18 1 1 REG FILE 01 1 1 RES DIR 1 1 EXTERNAL: NRC PDR 02 TOTAL NUMBER OF COPIES REQUIRED: LTTR 7 ENCL 7

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'gP JUL -5 P4:32 i-pr'!< jlG;., ":i ~<"I"..1 L-90-24/; .

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JUHE~ 2 9 1990 Mr. Samuel J. Chilk Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn: Docketing and Service Branch Re: Notice of Receipt of Petition for Rulemaking Revisions to Final Safety Analysis Reports, 10 CFR Part 50 55 Fed. Reg. 18608 May 3, 1990 Re uest for Comments

Dear Mr. Chilk:

h These comments are submitted by Florida Power & Light Company (FPL) in response to the request of the U. S. Nuclear Regulatory Commission (NRC) for comments on a petition for rulemaking concerning the frequency of Final Safety Analysis revisions under 10 CFR Part 50 (55 Fed. Reg 18608 Report May 3, 1990).

(FSAR)

FPL is an investor-owned utility serving over'hree customers in the State of Florida. FPL is a licensed operator of (3) million two nuclear power plant units in Dade County, Florida and two units in St.- Lucie County, Florida.

In its petition, Yankee Atomic Electric Company seeks a change to the current requirements of 10 CFR 50.71(e)(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 planned refueling outage. FPL supports a change to 10 CFR 50.71(e)(4) and believes that significant benefits can be gained from the adoption of the petitioner's request.

The Nuclear Management and Resources Council, Inc. (NUMARC) has offered comments on the subject proposed rule. NUMARC recommends that the wording of the proposed rule change provide flexibilityto permit a licensee to submit more frequent FSAR updates in lieu of post-outage revisions if desired. Further, NUMARC suggests that because of the number and complexity of modifications that may be accomplished in a refueling outage, it is recommended that the FSAR revision be submitted within nine months following an outage as 9007180080 900b29 PDR PRN 50-55 PDR an FPL Group company

l Mr. Samuel J. Chilk L-90-241 Page two opposed to the six months requested by the petitioners.

Accordingly, the following revised wording to 10 CFR 50.71(e)(4) is suggested by NUMARC:

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 of one of the facilities to establish the schedule for revisions of the common FSAR.

FPL supports the NUMARC comments and revised wording to 10 CFR 50.71(e)(4).

In conclusion, FPL supports the petitioner's position that the requested change (as revised by NUMARC) to 10 CFR 50.71 would be beneficial to both the NRC and the industry. The resulting longer interval between FSAR updates would benefit many licensees by reducing the administrative costs associated with preparation of the FSAR updates. Additionally, NRC staff time for FSAR reviews would be similarly reduced.

FPL appreciates the opportunity to comment on the petition for rulemaking. We would welcome the opportunity to discuss our comments with the NRC staff.

Very trul yours, H. Bohlke Vice President Nuclear Engineering and Licensing

Stephen B. Bram~ , GCKE-. >HIIviBt=R Vice Preskfont TIONRULE HM-58

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Consolidated Edison Company of New York. Inc.

LOf:ht. iLit Indfan Point Station 'SHHC Broadway & Bleakley Avenue Buchanan, NY 10511 June 29, 1990 Telephone (914) 737-8116 '90 Jl/L -5 P4:29 Mr. Samuel J ~ Chilk Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Docketing and Service Branch

Subject:

Notice of Receipt of Petition for Rulemaking Regarding 10 CFR 50.71(e)(4)

Docket No. PRM-50-55 Request for Comments (55 Fed. Reg. 18608, May 3, 1990)

Dear Mr. Chilk:

On May 3, 1990 the Nuclear Regulatory Commission ("NRC") published in the Federal Re ister (55 Federal Register 18608) a request for comments on a petition for rulemaking concerning the frequency of Final Safety Analysis Report ("FSAR") revisions under 10 CFR Part 50.

The requested rule change would provide that such revisions be filed no later than six months after completion of each refueling outage for the subject facility. Pursuant to the notice, Consolidated Edison Company of New York, Inc. ("Con Edison" ), as holder of Operating License 50-247 for Indian Point Unit No. 2, is pleased to provide the following comments.

Con Edison supports the petition for rulemaking, believes it to be sound in its underlying logic and of substantive potential benefit to the NRC and the industry. In addition to its benefit in terms of reduced cost and resource requirements, experience has shown that the outage at the end of an operating cycle is the most likely time for significant plant changes to be implemented. The completion of such an outage is, therefore, a more natural demarcation point for plant changes to be included in the FSAR revision process and would have the added benefit of reducing the average time between implementation of such changes and documentation of those changes in the FSAR.

To take full advantage of the benefits that would result from this change, however, Con Edison wishes to point out the need for concurrent changes to 10 CFR 50.59(b). That section currently requires a similar reporting of plant changes on an annual basis.

Without a concurrent change to an operating cycle frequency for reporting under this section, a disconnect would evolve which could detract from and diminish the advantages of the change being sought.

Mr. Samuel J. Chilk "2- June 29, 1990 In addition, 10 CFR 50.71(e)(2) requires that FSAR submittals include identification of changes made under 10 CFR 50.59 but not previously submitted to the NRC. With non-coextensive submittal frequencies, the probability of having to provide additional reporting under 10 CFR 50.71(e)(2) would increase as would the administrative burden associated with tracking to assure compliance with that requirement.

Con Edison is also a member of the Nuclear Management and Resources Council, Inc. ("NUMARC") and fully supports the comments being provided separately by NUMARC regarding this petition.

Notwithstanding the additional changes recommended in our above comments, we wish once again to state our support for the petition.

We hope that the above comments enhance the potential benefit to be derived from any proposed rule change. We appreciate the opportunity to comment and would be pleased to discuss our comments further.

Very truly yours, cc: Senior Resident Inspector U.S. Nuclear Regulatory Commission Post Office Box 38 Buchanan, New Xork 10511

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