United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 456: FSARs for Part 50 power reactor licensees

typically contain multiple references to current 10 CFR

Part 20 concepts and terminology, primarily with regard to

describing aspects of the radiation protection program.

Updating of these references would be editorial in nature,

without any health and safety benefit, but would

nevertheless divert resources from potentially more

significant matters. Additionally, these changes would be

submitted to the NRC as part of the FSAR Update process,

involving NRC staff review, an additional expenditure of

resources. May licensees forego such editorial changes to

the FSAR, that have no health and safety significance? Note

that programmatic changes required to implement the revised

Part 20 will still be accomplished through new or revised

procedures and training. Additional clarification of the

NRC staff's expectations would be useful for Part 50

licensees to more appropriately efficiently allocate

resources to their revised Part 20 implementation efforts.

Answer: Yes; power reactor licensees do not need to

provide updates that are purely editorial and have no

health and safety significance. 10 CFR 50.71 (e) requires

each power reactor licensee to update the licensee's FSAR

and to submit the changes to the NRC. The only FSAR

changes (resulting from the revised Part 20) that need to

be made are: (a) significant changes in commitments

identified in the FSAR regarding the radiation protection

program; b) changes in the facility described in the FSAR;

and (c) changes that involve an unreviewed safety question

or technical specification change pursuant to 10 CFR 50.59.

The NRC staff does not expect that implementation of

revised Part 20 will result in significant changes to power

reactor facilities or in unreviewed safety questions at

these facilities. Changes in reactor technical

specifications are not required by the revised Part 20;

however, the staff does expect that some power reactor

licensees will voluntarily request changes in technical

specifications as a result of revised Part 20, such as

changes in ESF-related process monitor alarm set points

which may have been based on the old Part 20). (Reference:

10 CFR Part 50, FSAR).

Page Last Reviewed/Updated Thursday, March 29, 2012