ML20205A646
| ML20205A646 | |
| Person / Time | |
|---|---|
| Issue date: | 10/30/1998 |
| From: | Mizuno G 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 AG12-1-013, AG12-1-13, NUDOCS 9903310036 | |
| Download: ML20205A646 (1) | |
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From: Geary Mizwo To: David Matthews, Frank Akstulewicz, Steve LaVie, . ,
- Date: 10/30/98 9:14am
Subject:
Re: Revised Source Term Proposed Rule Coordination -Forwarded -Reply From Tom Bergman >na. 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?<<<
At I discussed with Tom yesterday, determining whether the UFSAR has been updated correctly to raMeet the proposed change which is the subjec.' matter of the amendment requestis not inconsistent with the intent of the 50.71(e) rule. The SOC for the 50.71(e) rule (which everyone should carefully read), focuses on the utility commenters (valid) concem that the NRC would be conducting " licensing reviews" of FSAR updates - which I !
l interpret to mean substantive re-reviews of the merits of changes made pursuant to 50.59, as well as re-reviwing the merits of changes already approved. The Cornmission stated that such re-reviews were not intended. My position is that the licensee has come in with a proposed change to its licensing basis, and therefore a review of only that
[ portion of the FSAR which must be changed to accurately reRect the subject of the license amendmentis not l l the kind of"liconesing review of FSAR updates which the Commission disavowed in the 50.71(e) rulemaking.
>nc. The staffs review should focus on the change to the facility, not the change to UFSAR. Licensee's don't (shouldn't) modify the UFSAR, then modify the facility. The modification to the facility drives the change to the l UFS AR. 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 compliance 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.<<<
l The requirement for review and approval in Section 50.59 involves changes to the facility which are inconsistent with the description in the FSAR. Thus, it is entirely logical to not only look at the adequacy of the change itself, but also
- the accuracy of the FSAR's description of the change. In initial licensing, the Staff surely reviews the accuracy of the
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! FSAR. Why should the Staff not bother with its accuracy for subsequent licensing actions? That the Staffs practice l V has been otherwise in itself does not justify its continuance.
l CU: Eileen McKenna, Stewart Magruder )
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