ML20154J055
| ML20154J055 | |
| Person / Time | |
|---|---|
| Issue date: | 10/08/1998 |
| From: | Essig T NRC (Affiliation Not Assigned) |
| To: | Pietrangelo A NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| PROJECT-689 NUDOCS 9810150155 | |
| Download: ML20154J055 (9) | |
Text
- _ _.
october 8, 1998 Mr. Anthony R. Piatrangslo
- Director, Licensing Nuclear Energy Institute Suite 400 1776 "l" Street, NW Washington, DC 20006-3708
SUBJECT:
NRC STAFF COMMENTS ON FINAL DRAFT REVISION 0 OF NEl 98-03,
" GUIDELINES FOR UPDATING FINAL SAFETY ANALYSIS REPORTS"
Dear Mr. Pietrangelo:
Enclosed are issues identified by my staff with regard to the Final Draft Revision 0 of NEl 98-03,
" Guidelines for Updating Final Safety Analysis Reports," which was provided to the staff by your letter dated September 30,1998. In order to meet your requested schedule for comments, the review of the Final Draft Revision 0 was limited to my staff. Upon receipt of Revision 0 and a request for endorsement, NEl 98-03 will be reviewed by the NRC staff.
Also included in the enclosure is an evaluation of the extent to which NEl has addressed the staff's previous issues provided in a letter dated September 1,1998. All but two of the issues raised in the September 1,1998, letter are considered closed.
The staff has identified 19 new issues on the Final Draft Revision 0. Consistent with prior practice, the issues have been categorized as either a comment, suggestion, or editorial change. Comments must be addressed acceptably in order for the staff to endorse NEl 98-03 without exceptions, if you have any questions, please contact Tom Bergman at (301) 415-1021, or email tab @nrc. gov.
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Sincerely, _
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Original Signed By:
Thomas H. Essig, Acting Chief
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Generic Issues and Environmental i
Projects Branch
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Division of Reactor Program Management Office of Nuclear Reactor Regulation
Enclosure:
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STAFF ISSUES ON NEl 98-03 i
The staff reviewed the Final Draft Revision 0 of NEl 98-03 to determine whether the staffs j
. issues provided previously had been incorporated. Except as noted below, all previous staff 1
issues have been resolved, or are being addressed through a new issue. Although some of the 4
staff s editorial changen and suggestions were not incorporated (the staff is continuing to use comment, suggestion, and editorial changes in the same manner as defined in the September 1,1998, letter), the staff will not readdress those issues as they were left to NEl.
l.
j Consistent with prior practice, new issues identified during the review of the Final Draft i
Revision 0 of NEl 98-03 will begin with comment number 48. The status of each of the j
comments that were open in the. September 1,1998, letter are as follows:
Status Of Prior Open Comments (all others were closed in the Draft Revision 0) 6.
Terminoloav should be consistent throuahout the auidance document 4
Closed.
]
23.
Temoorary Chanaes
[
4 Closed. The staff also provided more specific language in Comment 37. Although NEl did not make the specific changes suggested by the staff, the alternative proposed by NEl appears acceiptable.
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~ 27.
Definition of "Oriainal FSAR" i
Closed. The staff's suggested change was incorporated. In addition, an additional statement was made specific to early licensees that cppears acceptable.
1 i
1 j
28.
Definition of " Limits on Ooeration" i
Open. NEl has proposed to envelop the operating limits definition proposed by the staff i
into a definition of"UFSAR description." While the staff finds this proposed attemative d
suitable, it appears that this modification was not consistently incorporated throughout j
the document. The staff provides specific additional comments in issues 48,51, and j
60.
29.
Definition of " safety analvses" Open. NEl made the modification suggested by the staff. However, upon further review, the staff has identified an editorial change to the previously proposed definition, and requests that NEl modify the first sentence as follows: " Safety analyses are j
analyses performed pursuant to Commission requirement to demonstrate the integrity of tne reactor coolant pressure boundary, the capability to r,hutdown the reactor and j
maintain it in a safe shutdown condition, eneor the capability to prevent...."
ENCLOSURE
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Q tto UNITED STATES E*
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001
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October 8, 1998
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Mr. Anthony R. Pietrangelo Director, Licensing Nuclear Energy Institute Suite 400 1776 "l" Street, NW Washington, DC 20006-3708
SUBJECT:
NRC STAFF COMMENTS ON FINAL DRAFT REVISION 0 OF NEl 98-03,
" GUIDELINES FOR UPDATING FINAL SAFETY ANALYSIS REPORTS"
Dear Mr. Pietrangelo:
Encloscd are issues identified by my staff with regard to the Final Draft Revision 0 of NEl 98-03,
" Guidelines for Updating Final Safety Analysis Reports," which was provided to the staff by your letter dated September 30,1998. In order to meet your requested schedule for comments, the review of the Final Draft Revision 0 was limited to my staff. Upon receipt of Revision 0 and a request for endorsement, NEl 98-03 will bc reviewed by the NRC staff.
Also included in the enclosure is an evaluation of the extent to which NEl has addressed the staff's previous issues provided in a letter dated September 1,1998. All but two of the issues raised in the September 1,1998, letter are considered closed.
The staff has identified 19 new issues on the Final Draft Revision 0. Consistent with prior practice, the issues have been categorized as either a comment, suggestion, or editorial change. Comments must be addressed acceptably in order for the staff to endorse NEl 98-03 without exceptions.
If you have any questions, please contact Tom Bergman at (301) 415-1021, or email tab @nrc. gov.
Sincerely, Thomas H. Essig, Acti Chief Generic issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Reguistion l
Enclosure:
As stated i
cc w/ encl: See next page t
e 2
35.
Level of detail for new issues j
Closed. NEl has proposed an attemative approach that appears acceptable.
a.
1 37.
Section 8. Treatment of Lona-Term Temocrary Modific.ations Closed. See comment 23.
i
~ New NRC Staff issues on Final Draft Revision 0 of NEl 98-03 (in order of appearance) 48.
Definition of "UFSAR Descriotion" (comment) i The definition should be modified as follows to more clearly reflect what is expected to be described in a UFSAR, and to build upon definitions in the regulations for safety related and design basis events:
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}
UFSAR description includes text, tables, diagrams, etc., that i
provide an understanding of the design bases, safety analyses and facility operation during and following design basis events.
i For purposes of this guideline, design basis events are the same i
as those described in 10 CFR 50.49(b); that is, conditions of j
normal oparation, including anticipated operational occurrences, design basis accidents, extemal events, and natural phenomena j
for which the plant must be designed to function.under narra;' ;nd I ;,,C.,: ;;.,C;T,;.
)-
49.
Section 5.0. naae 4. last bullet (comment)
!l To be consistent with the formatting of the sentence leadirig to the bullets, and to conform to the proposed change in comment 48, replace the existing text with,
" description as defined in Section 3.0."
50.
Sg;1jon 6.0.oiae 7. 3rd bullet under item 1 (editorial change)
To be consistent with section numbering in the guideline, the third bullet should be revised to read:
appropriate UFSAR description as defined in Section 3.0 of this guideline.
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51.
Section 6.0. caos 7. last caraaraoh under item 2 (comment)
This paragraph should be modified to return to language similar to that in the Draft Revision 0, and modified to conform to the proposed change in comment-48, as follows:
i If a change or supporting safety evaluation does not affect existing UFSAR informationdesenphen and does not result in new design bases-er, safety analyses, or UFSAR description, then the UFSAR does not need to be updated to reflect the change.
52.
Section 6.0. Daae 8. first bullet under item 3 (comment)
Altnough present in Draft Revision 0, the first bullet should be deleted as it is unnecessary, and may in'roduce confusion with the reference to item 2. The current t
second bullet and last paragraph should be combined into the first paragraph.
Suggested wording is as follows:
?
This includes the effects of analyses or similar evaluations performed by licensees in response to plant-specific NRC requests or NRC generic letters or bulletins. NRC-requested analyses and evaluations must be reflected in UFSAR updates if, on the basis of only if they h;;; en; or 4
both of th; f;ll;;;lng ;";;;;, n opp ll=ble:
The llc;nn; nltl::= ; chag; t; th: f;;;'lty ;r preadura bn;d l-en the r;;ult; cf th; aquat;d en;'y;l; cr ;;;'at ;n The ch;ng;==t b; cv;lc;t;d under lt;m 2, ;b;;;, to d;;;;m:n; F upd;;; cf the UFO? R :: requlr:d.
0;;;d en the results of the requested analysis or evaluation, the i
licensee determines that the existing design bases, safety l
analyses or associated UFSAR description in the UFSAR are either not accurate or not bounding or both. The existing design 4
bases, safety analyses and UFSAR description must be updated to reflect the new information, as appropriate. Changes to the i
UFSAR must be made in accordance with applicable change i
control requirements.
If the NRC-requested analyses or evaluation do not cause any of thesethe effects ldentP:cd ;bev;, then no upd;;; cfchange to the UFSAR is required.
i 53.
' Section 6.2. Daae 9. second oaraaraoh of the examole in CASE 1 (editorial change) i in the second sentence of this paragraph, Generic Letter 96-01 is misidentified as j
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4 54.
Section 6.2. Dage 10. f ast caracraoh in examole for CASE 2 (editorial change)
As presently worded, the last paragraph could be misinterpreted as meaning that a l
periodic update was not required. Suggest the language be modified to be similar for CASE 1, such as, ".. then no updct; cfchange to the UFSAR is required."
55.
Sglipn 6.2. Daae 10. last sentence in examole for CASE 3 (editorial change)
For clarity, propose the sentence be modified as follows: "...new ATWS equipment chould be cdded towould be required to be included in the UFSAR."
56.
Section 6.2. Daae 11. last sentence in examole for CASE 4 (editorial change) l For clarity, propose the sentence be modified as follows: "..affected by FFD program implementation, no update sfadditionalinformation would need to be added to the UFSAR4s-rcqu; red as a result of the new requirement."
57.
Section 7.0 (comment) l As noted in the proposed generic letter, the staff may have provided informal guidance to licensees ir.dicating exemptions were not necessary. Therefore, Section 7.0 must be clear as to what constitutes " proper approval." Section 7.0 should be modified as l
follows:
As required by 10 CFR 50.71(e)(4), licensees are required to submit a periodic UFSAR update annually or within 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months. Licensees may devieterequest an exemption from this requirement w';th propcr cpprovc: from the NRC. For example, the NRC has cpprovedgranted exemptions that allow the licensee rcquc;t; to submit a single, combined periodic update for multi-unit plants with a common UFSAR.
58.
Section 8.0. Daae 11. first caracraoh (editorial change)
For clarity, propose the following be added at the end of the last sentence, "and to be evaluated in accordance with 10 CFR 50.59 for determining whether prior staff approval is required."
59.
Section 8.0. oaae 12. first caraaraoh (editorial change)
)
The last sentence could be interpreted to require licensees to submit copies of the entire safety evaluations performed in accordance with 10 CFR 50.59, rather than a summary report as required by 10 CFR 50.59(b). Suggest this sentence be modified to read,"For i
temporary changes subject to 10 CFR 50.59, safety evaluations are performed and a i
summary report submitted to the NRC in accordance with 10 CFR 50.59(b)(2).
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60.
Section 8.0. Examole 2. first caragraoh on oage 13 (comment)
Consistent with the changes described in Comment 48, the paragraph should be revised as follows:
Because the modification does not cause inforrn; tion contained in the UFOAR to bc incorrect, and doc: not a"cci the ;cfcty anc'y;;; or dc;l;;n base, affect existing UFSAR information and does not result in new design bases, safety analyses, or UFSAR description, this modification would not be reflected in the next required UFSAR update.
61.
Section A-2. oaae A-1. third bullet (editorial change)
For clarity, propose the third bullet be revised to read, "As discussed in Section A-6, Heeneeesthe NRC should identlfy to the NRCbe informed of information removed.. "
62.
Section A-3. Daae A-2. second and third full caragraohs (comment)
This section of NEl 98-03 was substantially revised from the Draft Revision 0. The staff recommends that the language in this section be restcred to that in Draft Revision 0.
Specifically, the second and third paragraphs, beginning "By definition.." and
" Licensees are not..", respectively, should be deleted and replaced with the paragraph that preceded the examples in Draft Revision 0. In addition, the final paragraph in Section A-3 of Draft Revision 0, which has been deleted from the Final Draft Revision 0, should be restored (modified as suggested in Issue 40).
The principal concern with the language proposed in the Final Draft Revision 0 is that it attempts to introduce a significance test into the need to reflect changes in the next periodic update; 10 CFR 50.71(e) does not have a significance test. Second, while the new language identifies to licensees that 10 CFR 50.71(e) continues to apply (at least for the undefined significant changes), it does not incorporate the statement that
" reformatted information remains subject to all applicable requirements, including 10 CFR 50.59 and 10 CFR 50.71(e)." (changes reflect proposed modifications in issue 40) 63.
Section A-3. oage A-2. statement orecedina examoles (editorial change)
Suggest that this statement be modified to read, "The following are potential examples of historicalinformation:" The staff will not review the acceptability of the examples for all cases. As discussed below in Issue 66, a general statement about the applicability of examples should also be incorporated into NEl 98-03.
64.
Section A-4.1. Dage A-3. last caraaraoh (editorial change)
Similar to the preceding issue, suggest that the first sentence be modified to read, "The following types of excessively detailed textual information may be considered for removal removed from UFSARs,..."
6 65.
Section A-4.1. Daae A-4. third bullet (comment)
As requested by Issue 43, examples were added for all the bullets in this section, however, in the case of the third bullet, the example improperly restricts updating of UFSAR information to safety functions. This should be modified to read, "... do not contain equipment that performs design basissefety functions."
66.
General Comment. Aoolicability of Examoles (suggestion)
A general statement concerning the applicability of examples should be made. For example, "The examples provided in NEl 98-03 are for illustrative purposes only, and do not necessarily apply to alllicensees. Licensees must evaluate the suitability of the examples to the specific circumstances of their facilities."
4
m i
. Nuclear Energy Institute Project No. 689 cc:
Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy Institute Suite 400 Suite 400_
1776 i Street, NW 1776 i Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy Institute ABB-Combustion Engineering, Inc.
- Suite 400 12300 Twinbrook Parkway, Suite 330 l
1776 i Street, NW Rockville, Maryland 20852 Washington, DC 20006-3708 Mr. David Modeen, Director Engineering Nuclear Energy Institute
. Suite 400 1776 l Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director Licensing Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparuto, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 4
.n.
.