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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).