Health Physics Questions and Answers - Question 456

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)