ML20002D588
Text
.
ALL POWER REACTOR LICENSEES Docket No. 50-348 Docket No. 50-3 Farley Unit 1 Indian Point Unit 1
' Docket No. 50-313 Dccket No. 50-247 Arkansas Unit 1 Indian Point Unit 2 G
Docket No. 50-368 Docket 50-286 E2 Arkansas Unit 2 Indian Point Unit 3 p3 t.
_y
.~
Docket No. 50-317 Docket No. 50-155 r3 ca Calvert Cliffs Unit 1 Big Rock Point U'a Docket No. 50-318 Docket No. 50-255
"[
N O
Calvert Cliffs Unit 2 Palisades ii,g m
x Docket No. 50-292 Docket No. 50-409 Pilgrim Unit 1 Lecrosse Docket No. 50-325 Docket No. 50-269 Brunswick Unit 1 Oconee Unit 1 Docket No. 50-324 Docket No. 50-270 Brunswick Unit 2 Oconee Unit 2 Docket No. 50-261 Docket No. 50-287 H. B. Robinson Unit 2 Oconee Unit 3 Docket No. 50-10 Docket No. 50-334 Dresden Unit 1 Beaver Valley Unit 1 Docket No. 50-237 Docket No. 50-302 Dresden Unit 2 Crystal River 3 Docket No. 50-249 Docket No. 50-335 Dresden Unit 3 St. Lucie Unit 1 Docket No. 50-254 Docket No. 50-250 Quad-Cities Unit 1 Turkey Point Unit 3 Docket No. 50-265 Docket No. 50-251 Quad-Cities Unit 2 Turkey Point Unit 4 Docket No. 50-295' Docket No. 50-321 Zion Unit 1 Edwin I. Hatch Unit 1 Docket No. 50-304 Docket No. 50-366 Zion Unit 2 Edwin I. Hatch Unit 2 Docket No. 50-213 Docket No. 50-315 Connecticut Yankee (Haddam Neck)
D. C. Cook Unit 1 610121 u4 4 5 f
.p o
. Docket No. 50-316 Docket No. 50-344 D. C. Cook Ur.it 2 Trojan Docket No. 50-331 Docket No. 50-333 Duane Arnold FitzPatrick Docket No. 50-219 Docket No. 50-267 Oyster Creek Unit 1 Ft. St. Vrain Docket No, 50-309 Docket No. 50-272 Maine Yar.kee Salem Unit 1 Docket No. 50-289 Docket No. 50-244 Th'ree Mile Island Unit 1 R. E. Ginna 1 Docket No. 50-320 Docket No. 50-312 Three Mile Island Unit 2 Rancho Seco Docket No. 50-298 Docket No. 50-206 Cooper Station San Onofre 1 Docket No. 50-220 Docket No. 50-259 Nine Mile Point Unit 1 Browns Ferry Unit 1 Docket No. 50-245 Docket No. 50-260 Millstone Unit 1 Browns Ferry Unit 2 Docket No. 50-336 Docket No. 50-296 Millstone Unit 2 Browns Ferry Unit 3 Docket No. 50-263 Docket No. 50-346 Monticello Davis-Besse 1 Docket No. 50-282 Docket No. 50-271 Prairie Island Unit 1 Vermont Yankee Docket No. 50-306 Docket No. 50-338 Prairie Island Unit 2 North Anna 1 Docket No. 50-285 Docket No. 50-280 Ft. Calhoun Surry Unit 1 Docket No. 50-133 Docket No. 50-281 Humboldt Bay Surry Unit 2 Docket No. 50-277 Docket No. 50-266 Peach Bottom 2 Point Beach Unit 1 Docket No. 50-278 Docket No. 50-301 Peach Bottom 3 Point Beach Unit 2 1
3-1 1
Docket No. 50-305 Kewaunee Docket No. 50-29 Yankee-Rowe t
9 8
O G
G l
l
f1ja acg),
UNITED STATES y
g NUCLEAR REGULATORY COMMISSION E
WASHINGTON, D. C. 20555
/
December 15, 1980 i
i ALL OPERATING REACTOR LICENSEES Gentlemen:
RE: PERIODIC UPDATING 0F FINAL SAFETY ANALYSIS REPORTS (FSARs)
The Commission approved the rule 50.71(e) (copy enclosed) entitled,
" Periodic Updating of Final Safety Analysis Reports" and published the rule in the Federal Register on May 9, 1980. The rule became effective on July 22, 1980.
In accordance with the rule, licensees of Systematic Evaluation Program (SEP) plants have been notified by separate letters that they need not comply with the provisions of the rule until the program has been com-pleted.
For non-SEP plants, the rule requires submittal of the updated FSAR within 24 months of either July 22, 1980, or the date of issuance of the operating license, whichever is later.
Although the rule is essentially self-explanatory, several questions have been asked regarding the FSAR's legal status, format and content, and we have provided the enclosed guidance.
Furthar questions should be directed to the Project Manager for your facility.
Sincerely, d
(M
.isenhut, Directo'r "Darrell G.[ Licensing Division of
Enclosures:
As Stated l
l l
l t
e c
D cW o
a 30614 Federal Register / Vol. 45. No. 92 / Friday. May 9.1960 / Rules and Regulations cupm.ausNTAny INronuArion:On which theMC staffis making a November 8.1976, the Nuclear systematic safety evaluation of eleven Regulatory Commission published in the (11) nuclear power facilities !! censed for Federal Register (41 FR 49123) a notice operation before 1972. The purpose of of proposed rule making inviting written this systematic evaluation program suggestions or comments on the (SEP)is to determine and document the proposed rule by December 23.1976. A degree to which the eleven (11) facilities j
notice of correction and extension of meet current licensing requirements for 1
comment period was published in the new plants. Of the five (5) plants Federal Register on December 27.1976 licensed prior to January 1.1963 that are
{41 m 56204)in which the comment stilllicensed to operate, three (3) are period was extended to January 26.1977. included in the SEP.%e remaining two The notices ccncerned proposed (2) plants.8 which presently are shut t
amendments to 10 CR Part 50.
down. will be subject to the provisions "Ucensing of Production and Utilization of the rule as long as their licenses Facilities." to require each appliceT for, authorize operation.
or holder of, a power reactor operAng The licensees participating in the SEP license which would be or was issued probably will be requested to supply a after January 1.1963 to submit considerable amount ofinformation periodically to the Commission revised. during the program. Requiring them. in pages for its Final Safety Analysis addition. to update their FSARs could Report (FSAR). These revised pages prove to be excessively burdensome and would indicate changes made in the could result in duplication of reports.
facility or the procedures for its The inforsantion generated during the operation and any analyses affected by program and the manner in which it is NUCLEAR REGUI.ATORY these changes. nitty-one persons collated will result in a completed FSAR COMMISSION submitted comments regarding the at the conclusien of the program. For proposed amendments. He commenters these m== Heensus of fac$ ties to CFR Part 50 could be roughly divided into three being sub}ected by the NRC to a I
groups with seventeen supporting the systematic evaluation pmgra.n will not Periodic Updattr* 3 of Finsi safety rule with comments, eleven opposed to be required to comply with the Analysta Reports the rule, and three neutral Copies of the
'I com e re e ed y be exa edin f]((.S.NucleatRegulatory ed by et b th R sD ctor of the Office of Nuclear Reactor Room at 1717 H Street. NW
action: Final rule.
Regulation that, for their particular Washington. D.C.
suuuany:%e Nuclear Regulatory The s'ubstantive areas of comment can facility, the pmgram has been ca e of th Commission is amending its regulations be categorized generally as follows:
] mete p
to require each person !! censed to Canfication of Rule w
1' Ap;1icability of Rule f the proposed rule. hichlimited the operate a nuclear power reactor to m
applicability to facilities licensed after submit periodically to the Commission
- 3. Content of NAR revised pages for its Final Safety
- 4. Scope of Rule January 1.1983 bas been deleted and the rule will apply to all power reactors Analysis Re port (FSAR). These revised
- 5. Tim.ns of submittals licensed to operate.
- 8. Relation of Rule to Other Rules and, pages will indicate changes which have ne MAR required to be updated by been made to reflect information and Re] orts ted FSAR the rule fa the original FSAR submitted analyses submitted to the Commission t/ Ben t of a as part of the application for the i
or prepared as a result of Commission In response to the comments received, operating license. it would not include requirement.The amendment is being the Commission is modifying the rule to the subsequent supplements and made to provide an updated reference (a) extend its applicability to all power amendments to the FSAR or the !! cense document to be used in recurnng safety reactors licensed to operate. (b) exclude that may have been submitted either in analyses performed by the licensee, the Commission. and other mterested applicants for operating licenses. (c) response to NRC questions or on the clarify the wording of the rule. (d) applicant's or licensee's own initiative l
parties. -
reduce its impact on power reactor following the ongmal submittal.These EFFaCTIVE oATE: July 22.1980.
beensees by relaxing some of the time various supplements and amendments Note.-De Nuclear Regulatory requirements, and (e) require the initial must be appropriately incorporated into ".
Commission has submitted this rule to the redsion to be a complete FSAR.
the originalFSAR to create a single
[C
",'}' Ith' E$po' When the proposed rule was complete and integral document. The published for public comment,its initial revision to be filed should contain Act. as amended. 44 U.Sc 3512. ne date on which the reportng requirement of this rule applicability was limited to those plants those pages from the originally becomes effectne. unless advised to the licensed after January 1.1963 in order to submitted FSAR that are still applicable centrary, accordingly. reflects inclusion of the exe=pt five (5) older facilities. ne plus new replacement pages that 45-day penod which that statute a!!cws for Commission believed that it would not appropriately incorporate the effects of such review (44 U.S.C. 3512(c)(2)).
be feasible for these licensees to supplements, amendments and other FoR FURTNER INFORMaTioN CONTACT:
implement the rule because there is no changes that have been made.This will Mr. Morton R. Fleishman. Office of integrated document comparable to an result in a single. complete document Standards Development. U.S. Nuclear FSAR for their facilities. Since Regulatory Commission. Washington.
publication of the proposed rule. the
.n. iwo r.cniii... andi n poini unit No.
D'C. 20555. telephone 301.443-5921.
Commission has '.titiated a program in
.nd Humbokis any Und No. 3
Federal Regis%r / Vol. 45. No. 92 / Friday. May 9.1980 / Rales and Raula. ions 30615 being filed, that can then serve as the be at least the same as origmally of license amendments and technical baseline for future changes.
provided. Minor differences between specification changes are independent Commenters have asked about the actual and projected population figures of the FSAR updating process and once proper format to be used when making or other such changes in the site approved would not be subject 'o t.e FSAR submittal. Since the format of environment need not be reported further consideration simply because the i
l the FSAR is not covered by regulation.
unless the conclusions of safety FSAR is updated.This, of course, does the rule does not specify a particular analyses relative to public health and not preclude the reevaluation of format.The NRC staff has provided safety are affected and the licensee has previcus positions based en new guidance for the preparation of FSARs prepared new analyses as a result of information or new considerations. De in Regulatory Guide 1.70. Revision 2.
NRC requiremen.s.
material submitted may be reviewed by
" Standard Format and Content of Safety Commenters have questioned the the NRC staff but will not be formally Analysis Reports for Nuclear Power relation of the proposed FSAR updating approved. The new pages will be Plants." However, many FSARs were requirements to other reporting accepted as representing the licensee's developed prior to any specific guidance requirements such as the Annual position at the time of submittal and will on format.The format to be used for the Operating Report and i 50.59(b) be utilized in any subsequent reviews or FSAR revisions is the option of the reporting. It is not the Commission's NRC staff activities concerning that licensee but the Commission expects intention to require submittal of facility.
that the format will probably be the duplicative reports. ne Cornmission is After consideration of the comments same as the format of the original FSAR. eliminatmg the requirement for the that were received and other factors, the No analyses other than those already Annual Operating Report.nis will Commission has adopted the prepared or submitted pursuant to NRC reduce significantly the reporting burden amendment to Part 50 as set forth requirements (either originally with the oflicensees. There has been no below.
application, or as part of the operating requirement that i 50.59(b) reporting be Pursuant to the Atomic Energy Act of license review process, or as required by part of the licensee's Annual Operating 1954, as amended. the Energy I 50.59 or other NRC requirement or to Report. This information generally has.
Reorganization Act of 1974. as amended, support license amendments) are been inc'uded in the Annual Operating and section 553 of title 5 of the United required to be performed by the hcensee Report as a convenience, but it could States C. ode, the follcwing amendment because of this rule.However, analyses have been submitted separately and the to 10 CFR Part 50 is published as a existing in the FSAR which are known licensee still would have complied with document subject to codification.
, to be inaccurate or in error as a result of f 50.59(b) which merely requires new analyses performed by the licensee reporting " annually or at such shorter PART 50--DOMESTIC 1.lCENSING OF pursuant to NRC requirements. would intervals as may be specified in the PRODUCTION AND UTILIZATION have to be revised. Specialized studies license." Furthermore, the report FACILITIES required under i 50.59(b)is only "a brief Section 50.71 is amended by adding a oc c h zard o un assurance, should include the latest information 8
new paragraph (e) to read as follows:
n i ngas the that has been developed in response to safety evaluation of each." The i 50.71 Maintenance of recorda, maWog of NRC requirements. New analyses (Le.'
l 50.59(b) reporting may not be detailed
- reporta, analyses not previously included in sufficiently to be considered adequate to fulfill the FSAR updating requirement.
(e) Each person licensed to operate a n ersti n f re ed s ty The degree of detail required for nuclear power reactor pursuant to the questions.8 technical specification updating the FSAR will be generally provisions of I 50.21 or i 50.22 shall changes, or other licensing questions, may be incorporated as appendices or greater than a brief description and a update periodically, as provided in otherwise appropriately inserted within
" summary of the safety evaluation.
paragraphs (e)(3) and (e)(4) of this the FSAR.
However, there n,s t.othing that precludes section, the final safety analysis report Program type material that is submitting the i 50.59(b) report along (FSAR) originally submitted as part of
- referenced by the FSAR. such as the with the FSAR update submittal and the application for the operating license.
Quality Assurance Program or the thus satisfy l 50.59(b) along with to assure that the information inchded Emergency lan, should be referenced i 50.71(e). Parts of the FSAR submittal in the FSAR contains the latest material p
accurately. lf such material has been may be referenced by the 150.59(b) developed. This submittal shall contain revised or amended. the latest revision report.
all the ci arms ec o sary to reflect l
ehould be referenced. A desenptics of Several commenters have raised legal infcrmatir >
Miyses submitted to physical changes to the facility should questions concerning the proposed rule the Corr w the licensee or I
be included in the updata after the including questions relative to the preparea '.c 9
<nsee pursuant to l
changes have been approved for use and -purpose of the rule. the implication Commission re quirem:mt since the l
are operable.The level of detail to be concerning re. reviews. the status of submission of the onginal FSAR or, as maintained in the updated FSAR should completed hearings. and prior license sppropriate, the last updated FSAR. The approvals. The rule is only a reporting updated FSAR shall be revised to
' As defined in I so.5ef aH21. A proposed chamae.
requirement to insure that an updated inc!ude the effects of: all changes made test or en:,ensent shall be deemed to involve an FSAR will be available. Submittal of in the facility or procedures as anreue=ed safety questson (ilif the probabihty of updated FSAR pages does not constitute described in $c FS" all safety a licensing action but is only intended to f c en o up et pc to ery evaluauens performed by $e licensee previously evaluated in the safety anaJysis repo t provide information. It is not intended entnerin support of reouested license may be it:c-ensei cr(d)if a possibtbry for an for the purpose of re-reviewing plants.
amendments or m suppcrt cf
,acc:de.-t or enahnction of a dSerent tpe than any Matters which have been considered conclusions that changes did not involve
' "P "
previously dunng heanngs will not be an unreviewed safety question; and all a
c s es or if e a of saf as ter.rie:: in tre bas.: for any techn. cal spec.fication reconsidered as a result of Me FSAR analyses of new safety issues performed
.s nsa:,d -
submittals. Thus. for example, approvals by or on behalf of the bcensee at
l 30016 Federal Rc;;is:er / Vol. 45. No. 92 / Friday. May 9.1980 / Rules and Regulations Comrn:: en reqaest.The updaied (Sec.181h.. Pub. Law 83-703. 88 Stat 948. Sec information shall be appropriately 201. Pub. Law S3-438. 88 Stat.1242142 U.S.C.
located withm the FSAR.
22011bl. 564111 (1) Revisions containing updated Dated at Washmston. D.C., this 1st day of information shall be submitted on a May 1980.
replacement.page basis and shall be For the Nuclear Regulatory Commission.
accomp.nied by a list whi h identifies Samuel [. Chilk.
the current pages of the FLAR followmg Secretaryofthe Commission.
page replacement. One signed original rnt om so-iens rii.a s-am s es and 12 additional copies of the required erumo cooc rse.e information sha!! be filed with the Director of Nuclear Reactor Regulation.
U.S. Nuclear Regulatory Commission.
~
Wa shington. D.C. 20555.
(2) The submittal shallinclude (i) a certification by a duly authorized officer of the licensee that either the information accurately presents changes made 3:nce the previous submittal, necessary to reflect information and analyses submitted to the Commission or prepared Wrsuant to Commission reyairemer.t. or that no such c.harigte were made: and (ii) an identification of Chen ca Ctece under the probisjons of s
f 30.59 b:t not previously submitted to the Commission.
[3)(i) A revision of the original FSAR contaming those original pages that are still applicable plus new replacement pages shall be filed within 24 mon'ths of either July 22,1980, or the date of issuance of the operating license.
whichever is !.ter, and shall bring the FSAR up to date as of a maximum of 6 me.aths prior to the date of filing the revisiott.
(ii) Not less than 15 days before 150.71(c) b.comes effectiee, the Director of the Office of Nuclear Reactor Regulation shall notify by letter the licensees of those nuclear power plants imtially subject to the NRC's systematic evalu.non program that they need not comply with the provisions of this section while the program ~is being condated at their plant.The Director of the office of Nuclear Reactor Regulation will notify by letter the licensee of each nuclear power plant being evaluated wh.n the systematic evaluation program has been completed. Within 24 months after receipt of this notification. the licensee shall fi!e a complete FSAR whicn is up to date as of a maximum of a man". ;r:et to the date of filing the re visa.r (41 S csequent revisions shall be Sled no le,. fre ;uently than artnually and shat! reIIe:t a:! changes up to a maximum Of 6 months pnor to the date of finric.
(5) Eaca eplacement page shall inciuce ben a change indicator for the area changed, e.g., a bold line vertically drawm in the margin adjacent to the portion actually changed. and a page change ident:fication (date of change or chang,e number or both).
Questions and Responses Concerning FSAR Update Rule A.
REGULATORY / LEGAL 1.
Question:
Is the updated FSAR part of the licensed basis of the plant? That is, can the original FSAR, as amended, be set aside and forgotten or is the license still based upon it?
E.g.,
for report-ing to NRC of deviations from conditions stated in the "FSAR," which.
one applies.
Response: The original FSAR, as amended, is still considered to be the licensing basis for the plant.
However, as indicated in the rule, the updated FSAR "shall contain all the changes necessary to reflect I
information and analyses subrsitted to the Commission....since'the sub-mission of the original FSAR...."
Furthermore, the rule requires cer-tification by the licer:see that the "information accurately presents changes made since the previous submittal, necessary to reflect infor-mation and analyses submitted (emphasis added) to the Commission...."
and an identification of changes made under 10'CFR 5 50.59. The NRC intends to use the updated FSAR in the future for appropriate applications such as reporting of deviations from conditions stated in the "FSAR."
If, as a result of possible audits, the NRC finds that the updated FSAR is not as certified to by the licensee, appropriate enforcement action would be taken.
1
i' 2.
Question:
Is the updated FSAR to be called the FSAR?
Response
The original FSAR and the docket file is the final author-ity if a discrepancy exists although the updated FSAR, which will be referred to as the updated FSAR, will provide the most convenient reference.
3.
Question: Who receives update?
E.g., do parties to the original proceeding, libraries, etc., receive a copy?
Response
As indicated in the rule, the licensee is only required to send the updated FSAR to the NRC.
There is no intention to send copies to parties to the original proceeding, u61ess such copies are requested in accordance with Commission regulations.
It is planned to place copies of the updated FSAR in the local public document room, the public document room in Washington, D. C. the Technical Information Center and the Nuclear Safety Information Center.
4.
Question:
In the future can the FSAR be used as the technical specification basis?
Response
The bases for the technical specifications are included along with the technical specifications.
If the technical specifi-cations have referenced the FSAR, they may continue to reference the updated FSAR.
5.
Question:
If environmental information (Chapter 2) has changed, is the ER or EIS affected in any way?
Response
The rule applies only to the FSAR.
The r;1e imposes no requirement to revise or update the Environmental Report or Environ-mental Impact Statement.
If a change was required, it would be as a result of other regulations.
2 I
\\'
6.
Question:
Relative to the frequency of the updating, what do the words "no less frequently than annually" mean?
Response
The time interval between submittals should not exceed 12 months.
8.
FORMAT 1.
Question:
For multiple unit stations with multiple FSARs:
Can they be combined into one FSAR, possible with colored pages?
(
Must the format for each FSAR be the same?
Response
To the extent that the plants on a multi-unit site are similar and have a good deal of identical information in their FSARs, the FSARs can be combined into a single updated FSAR, for convenience, with differences appropriately identified.
The formats for each updated FSAR do not have to be the same.
As indicated in the supplementary information, the format to be used is the option of the licensee.
2.
Question:
Do original questions and responses have to be maintained in any particular format, or at all?
Response
The original questions and the responses that were sub-mitted remain in the docket file as part of the record.
The re-sponses to the questions should be appropriately' incorporated into f
l the " body" of the updated FSAR.
No separate section is required.
l l
l 3
O 3.
Question:
Is the initial submittal of the updated FSAR treated as a revision of the original and nue.bered sequentially following the last revision or amendment?
Response
The initial submittal of the updated FSAR should be treated as a unique document and called the updated FSAR and not as a secuential revision of the original FSAR.
Subsequent changes should be considered revisions to the updated FSAR and should be N-numbered starting with revision No. 1.
4.
Question:
Are change bars and revision numbers required on the initial update or is it a " clean" document?
Response
The initial updated FSAR should be a " clean" document without change bars and revision numbers.
The subsequent annual revisions would then include the change indicators and page change identification.
5.
Question:
Can the initial updated FSAR be a complete, new, FSAR without retaining the old pages?
Response
The initial updated FSAR may be a completely new document without any of the origi al pages.
i C.
CONTENT 1.
Question:
Is the " drawing package" considered part of the FSAR?
Does it need to be updated?
Response
The " drawing package" is not considered part of the FSAR.
Only the drawings that are included in the FSAR should be updated.
4
2.
Question:
Can one eliminate information no longer applicable to an operating plant - e.g., initial training program, start-up test program, etc., assuming it is in the original FSAR? (Also construc-tion QA program)
Response
Information pertaining to programs described in the original FSAR with amendments, such as the initial training program and the preoperational test program, should be submitted as part of the initial updated FSAR for completeness.
The intent here is to locate previously submitted information in one document.
Submission of new information is not required.
The proposed technical specifi-cations may be eliminated since they have been superseded by tech-nical specifications issued by the Commission.
3.
Question:
If the original FSAR is in Regulatory Guide 1.70 format, do comparisons (e.g., to other plants) in Chapter 1 havs to be updated?
Response
The only changes that should be made should be to include all material submitted to the NRC. Only an administrative update is required.
The licensee should point out that the comparison was con-siderad valid at the time the operating license was issued.
4.
Question:
Will Security and Emergency Plans (Chapter 13) be treated separately?
gesponse:
T.he updated FSAR should reference the Security and Emer-gency Plans that are currently in effect.
5
5.
Question: Assuming portions of the plant or systems have been modi-fied and designed to codes then currently in effect, how is this addressed in the update?
Response
Identify whatever codes have actually been used to design or modify the plant.
If older codes were used for certain parts of the plant, it should be so indicated.
t 6.
Question: Assuming the original FSAR contains references that are no longer in use or acceptable in industry, must they be changed and the affected analysis revised accordingly? (For example, reference to a Corps of Engineers Technical Document on wave height analysis.)
Response
New analyses do not have to be performed and new refer-ences do not have to be incorporated just to comply with this rule.
Analyses should be revised if safety (i.e.,10 CFR S 50.59) or other considerations require such revision.
t e
6
-_ _