JPN-90-052, Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR

Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR

ML20063Q183
Person / Time
Site:	Indian Point, FitzPatrick
Issue date:	07/09/1990
From:	Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-55FR18608, RULE-PRM-50-55 55FR18608-00028, 55FR18608-28, IPN-90-037, IPN-90-37, JPN-90-052, JPN-90-52, NUDOCS 9008220215
Download: ML20063Q183 (3)

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-l lMr. Samuel J. Chilk Secretary / .

U.S. Nuclear Regulatory Commission ' ,j Washington, D.C. 20555 Attn: Docketing and Service Branch.

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Subject:

' Indian Point 3 Nuclear Power Plant +

Docket No. 50-286 James A. FitzPatrick Nuclear Power Plant Docket No. 50 333 '

. Comments on Petition for Rulemaking,

' Revisions to Final Safety Analysis Reports,10 CFR Part 50 - i i

Reference:

1. . Yankee Atomic Electric Company letter to NRC, dated February 9,1990, .

request for Petition for Rulemaking,10 CFR 50.71(e)(4). ,

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Dear Mr. Chilk:

The NRC has requested public comment on a petition for rulemaking submitted by the' Yankee Atomic Electric Company (Reference 1). The petition seeks to change the requirement -

that all operating nuclear power plants update the Final Safety Analysis Report (FSAR) "...no less frequently than annually." as required by 10 CFR 50.71(e)(4). ;The proposed change would revise this regulation to read "...shall be filed no later than six months after the completion of each -

planned refueling outage." The Authority endorses the proposed change and provides the following comments.

-Under the current regulatlorn there are situations in which an update could be required just prior to, or during, an outage. While the licensee could request an exemption to defer submittal of an updated FSAR from the NRC, it would simply consume resources that could be better -

. allocated towards moro important issues.;The adoption of the proposed change would allow- '

efficient allocation of resources with no compromise to public safety.  ;

.4, 55 9008020215 900709 PDR 50-55 PRM PDRj2;L

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Historically, major modifications are not installed during routine operation or mid cycle i outages. Most major plant modifications that affect the FSAR are installed during refueling l cutages. If a modification were installed after the January cutoff, the FSAR could be out of date i for as much as 18 months under the current regulation. Significant changes may not be -

incorporated in the FSAR for long periods. Unking FSAR updates to refueling outages would assure that major changes to the plant would be reflected within 6 months. In addition, updates can be most easily prepared following an outage when detailed information is readily available, The update schedule proposed by Yankee Atomic would supply both the NRC and licensee personnel with an accurate FSAR at the earliest possible time.

Should you or your staff have any questions regarding this matter, please contact Mr. J. B. Ellmers or Mr. P. Kokolakis of my staff.

Very truly yours, y

, ohn C. Brons

/ ecutive Vice President

(, Nuclear Generation cc: See next page l

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.. . 4 cc: Regional Administrator l U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident inspector U. S. Nuclear Regulatory Commission i P. O. Box 136 '

Lycoming, NY 13093 -

Mr. David E. LaBarge .

Project Directorate 11 Division of Reactor Projects t/II U. S. Nuclear Regulatory Commission Mail Stop 14 B2 .

Washington, D.C. 20555 l Resident inspector's Office t

. Indian Point 3 U.S. Nuclear Regulatory Commission P.O. Box 337 1 Buchanan, New York 10511 i 1 Mr. J. D. Neighbors, Sr. Project Manager i Project Directorate 11 Division of Reactor Projects-l/Il

U.S. Nuclear Regulatory Commission ,

Mail Stop 14 B2 Washington, D.C. 20555 i.

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