ML20203F159
| ML20203F159 | |
| Person / Time | |
|---|---|
| Issue date: | 01/05/1999 |
| From: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-99-001, SECY-99-001-01, SECY-99-001-R, SECY-99-1, SECY-99-1-1, SECY-99-1-R, NUDOCS 9902180068 | |
| Download: ML20203F159 (32) | |
Text
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RELEASED TO THE PDR .
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Januarv5.1999 SECY-99-001 FOR: The Commissioners FROM William D. Travers Executive Director for Operations
SUBJECT:
PROPOSED GUIDANCE FOR UPDATED FINAL SAFETY ANALYSIS REPORTS IN ACCORDANCE WITH 10 CFR 50.71(e)
PURPOSE:
To obtain the Commission's approval to issue the proposed draft regulatory guide (Attachment 1) for public comment.
SUMMARY
The staff recommends that the Commission approve issuance of draft regulatory guide (DG) 1083," Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e)," for public comment. DG-1083 endorses the industry guideline document developed by the Nuclear Energy institute (NEI), NEl 98-03, Revision 0, " Guidelines for Updating Final Safety Analysis Reports," dated October 1998 (Attachment 2), without exception. The staff believes that NEl 98-03 presents an acceptable tnethod for compliance with 10 CFR 50.71(e), g/
and also gives suitable guidance for modifying the content and format of the updated final safety analysis report (UFSAR') giving licensees considerable flexibility and the opportunity to reduce the burden associated with maintaining the UFSAR. In addition, the staff has discussed k with NEl the need for a clarification to be added to NEl 98-03, prior to the staff publishing the final regulatory guide, to state that the guideline is not intended to be used to remove information from UFSARs regarding SSCs that are risk-significant. While NEl did not commit to make the clarification until NEl discussed it with the task force that developed NEI 98-03, NEl did convey that the clarification would be consistent with the intent of NEl 98-03.
Contact:
Thomas Bergman, NRR (301) 415-1021
'The terminology for updated final safety analysis reports varies throughout industry.
l The terms updated FSAR, UFSAR, and USAR (updated safety analysis report) are equivalent.
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- The Commissioners 2 BACKGROUND:
1 Section 50.34 (10 CFR 50.34), " Contents of Applications; Technical Information," contains -
requirements for the material to be submitted in applications for construction permits and .
operating licenses for nuclear power reactors. An application for a construction permit must contain a preliminary safety analysis report (PSAR) pursuant to $50.34(a). An application for
- an operating license must contain an FSAR in accordance with $50.34(b). For holders of operating licenses, $50.71(e) requires the FSAR to be periodically updated (i.e., the updated ;
= Guidance for the organization and content of PSARs and FSARs has existed since June 30, i 1966, when the Atomic Energy Commission issued " Guide to the Organization and Contents of l
Safety Analysis Reports." The most recent guidance document is Regulatory Guide (RG) 1.70, ;
Revision 3, " Standard Format and Content of Safety Analysis Reports for Nuclear Power .
Plants, LWR Edition," dated November 1978. Limited guidance for the format and content of !
UFSARs was previously issued in Generic Letter 80-110. " Periodic Updating of Final Safety i Analysis Reports (FSARs)," dated December 15,1980.
j As a result of lessons loamed from the Millstone experience and from other initiatives related to UFSARs, the NRC determined that additional guidance was needed about compliance with
$50.71(e). The staff recommended specific actions in SECY-97-036," Millstone Lessons Leamed Report, Part 2: Policy issues," dated February 12,1997. In a staff requirements memorandum (SRM) dated May 20,1997, the Commission directed the staff, in part, to issue guidance for complying with $50.71(e) to ensure that UFSARs are updated to reflect changes to the design bases and to reflect the effects of other analyses performed since original licensing that should have been included under $50.71(e). The Commission suggested that this guidance should include a risk-informed approach for prioritization and content of the
. UFSAR, allow removal of certain information from the UFSAR, and consider whether the period of enforcement discretion regarding UFSARs should be extended. In the SRM dated March 24, 1998, concoming SECY-97-205," Integration and Evaluation of Results From Recent Lessons-Leamed Reviews," dated September 10,1997, the Commission reemphasized the need for
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guidance for UFSARs and further requested that guidance be prepared for plants undergoing decommissioning.
The staff responded, in part, to the May 20,1997, and March 24,1998, SRMs with SECY l 087. In that paper, the staff recommended that the Commission approve issuance of the staff's l proposed generic letter as interim guidance on the content of UFSARs. The staff further proposed to continue to resolve issues that the staff had with the preliminary version of NEl 98-03, with the goal of endorsing NEl 98-03 as the final guidance in a regulatory guide. The staff's proposed generic letter responded to the Commission's request for guidance on the content of the UFSAR, allowed removal of certain information, made the guidance applicable to plants undergoing decommissioning, and proposed a method for extending the enforcement discretion l u
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. Paragraph 50.71(f) extends the requirements of $50.71(e) to decommissioning !
facilities, i.e., those nuclear power reactor licensees that have submitted the certification of ;
permanent cessation of operations required under $50.82(a)(1)(i).
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i period for UFSARs that was risk informed (risk-informed prioritization). The staff noted that a risk-informed UFSAR content could not be achieved without rulemaking.
The staff recommended that the proposed generic letter be issued at th' at time because the staff could not endorse the preliminary version of NEl 98-03 without rulemaking. In particular, i' the staff had concerns with the industry positions regarding removal of certain historical information required to be in a UFSAR, removal of ill-defined " obsolete" and "less meaningful" information that may not have been allowed by the regulations, and the substitution of simplified schematics for piping and instrumentation diagrams (P&lDs) without ensuring that the UFSAR continued to contain all required information.
In an SRM dated June 30,1998, the Commission disapproved issuance of the proposed generic letter except under certain circumstances, and directed the staff to continue to resolve l differences between the proposed generic letter and NEl 98-03. The Commission also directed i
the staff to extend the enforcement discretion period for UFSARs for a 6- to 18-month period )
after the final guidance was issued, dependent on risk significance.8 l DISCUSSION:
1 The purpose of this paper is to obtain Commission approva! to issue DG-1083 for public !
comment. The proposed draft regulatory guide endorses NEl 98-03, Revision 0.
Staff /NEl Activities to Resolve issues and Develoo NEl 98-03. Revision 0 l i
NEl sent the staff a preliminary guidance document on November 14,1997. As noted above, the staff could not endorse that document without rulemaking unless certain positions'in the preliminary document were revised. On June 15,1998, the staff issued detailed comments on i the industry's preliminary guidance document. In general, these comments detailed the staff's ,
specific concerns about the preliminary guidance and noted where the preliminary guidance j document differed from the staff's proposed generic letter. i On July 8,1998, NEl submitted NEl 98-03, Draft Revision 0, " Guidelines for Updating Final Safety Analysis Reports," for staff comments. NEl stated that this document reflected reconciliation of differences between the industry's preliminary guidance and the proposed draft generic letter, as well as consideration of the staff's specific comments provided at a May 27, 1998, public meeting and in the June 15,1998, letter.
On September 1,1998, the staff issued its comments on NEl 98-03, Draft Revision O. These comments included input from all the regional offices, all technical divisions within the Office of Nuclear Reactor Regulation, and the Office of the General Counsel. In general, the staff found i that NEl had addressed the majority of the staff's earlier comments. Where differences still i existed, the staff elaborated on the justification for its positions, and offered specific !
recommendations for resolving the differences that remained. I l
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'The staff addressed thin item with Enforcement Guidance Memorandum 98-007, l
" Extension of Exercise of Diemaion for FSAR Discrepancies identified While the Licensee Has l a Defined Program for identifying Such Discrepancies," dated September 15,1998.
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Following a September 9,1998, public meeting between NEl and the staff, NEl submitted l
NEl 98-03, Final Draft Revision 0, on September 30,1998, for additional staff comment. In
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order to meet NEl's request for comments in time to issue NEl 98-03, Revision 0, at an i October 19,1998, workshop, the staff performed a limited review and provided its comments in l an October 8,1998, letter. ~i In a letter dated November 2,1998, NEl submitted NEl 98-03, Revision 0, to the staff for - !
endorsement in a regulatory guide. NEl stated that it had addressed all remaining comments in (
the staff's October 8,1998, letter. :
Summary of Guidance in NEl 98-03. Revision 0 - ;
in general, NEl 98-03, Revision 0 (hereafter Just NEl 98-03), contains guidance that is -
consistent with the guidance in the staff's proposed generic letter, although NEl has i substantially reorganized the guidance. NEl has organized its document into two parts: (1) information that is requited to be in a UFSAR and (2) an appendix containing optional activities that licensees may undertake to improve and simplify the UFSAR. The specific guidance begins in Section 3 (Sections 1 and 2 provide an introduction and background, respectively, not -
guidance) as follows: i Section 3, " Definitions" Definitions are provided (wMre appropriate, by reproducing the language from 10 CFR Part 50) ;
for Commission requirements, design bases, historical information, obsolete information, !
original FSAR, safety analyses, UFSAR description, and updated FSAR. )
l An area of discussion in the development of the guidance has been the definition of descriptive I information. NEl 98-03 addresses this issue by defining "UFSAR Description." UFSAR l description includes text, trbles, diagrams, etc., that provide an understanding of the design
. bases, safety analyses and facility operation under conditions of normal operation, anticipated operational occurrences, design-basis accidents, extemal events, and natural phenomena for which the plant is designed to functicn.
Section 4, " Role of the Updated FSAR" The updated FSAR is used by the NRC in its regulatory oversight and serves as a reference document for safety analyses performed by licensees, the staff, and others.
Sectron 5, " Scope of the Updated FSAR" Using the same approach as in the proposed generic letter, NEl 98-03 recognizes that the scope of an updated FSAR is generally defined by 10 CFR 50.34(b), and that this rule can be used to limit the amount of information that otherwise might be incorporated by 10 CFR 50.71(c). Essentially, 650.34(b) limits the revised and new information to be incorporated into ,
the UFSAR to the description of the facility, the design bases and limits on operation, and the l safety analyses of the structures, systems, and components and of the facility as a whole. l I
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The Commissioners 5 Section 6, " Updating FSARs to Meet 10 CFR 50.71(e)"
Guidance is provided on the requirements of 950.71(e) for information to be incorporated into the UFSAR and the level of detail necessary for updated and new information. Examples are given to illustrate the implementation of some of the guidarece. For the requirements of 950.71(e), NEl 98-03 elaborates on the language in the rule, which essentially states that licensees must update the UFSAR to reflect new or modified information that results from Commission requirements, changes to the facility in accordance with 10 CFR 50.59 and 10 CFR 50.90. and analyses of new safety issues requested by the Commission. For the level of dcta!!, !!censees may use the existing level of detail in their UFSAR as guidance, but the primary consideration is to ensure that the description is sufficient to permit understanding of new or modified safety analyses, design bases, and facility operation.
Section 7, " Frequency of Required Updates" The guidance restates the requirements on the frequency of submitting periodic updates, i.e.,
annually or within 6 months after each refueling outage, provided that the interval between I successive updates does not exceed 24 months. The guidance notes that the NRC has i granted exemptions to this requirement that allow some licensees to submit a single, combined periodic update for multiple-unit plants.
Section 8, " Treatment of Long-Term Temporary Modifications" The staff's position in its proposed generic letter was that temporary modifications should be i reflected in the UFSAR under any one of three criteria: (1) there is no schedule for removal of the temporary modification, (2) the temporary modification is not planned for removal until after l the next periodic update, or (3) the facility will not be restored to its condition as described in the current version of the UFSAR (i.e., a new design will replace the temporary modification).
NEl agreed that the first two criteria should be included in the UFSAR, but did not wish to l incorporate the third criterion into NEl 98-03. The bases for NEl's position were that the number of temporary modifications that would fall under the third criterion were relatively small, and often it was not until late in the process that a decision was made by the licensee as to whether the facility would be restored to its initial condition, the temporary modification would become the permanent condition, or a new design would be installed. Since the staff's principal concem with temporary modifications was the extended period some temporary modifications were left in place, and since this concern was addressed by the first two criteria, the staff agreed that the third criterion was unnecessary.
Section 9, " Treatment of Discrepancies Between the Facility and the Updated FSAR" The guidance in this section reminds licensees that discrepancies are to be treated in accordance with their corrective action program and, for degraded or nonconforming conditions, in accordance with Generic Letter 91-18, Revision 1.
Appendix A: " Modifying the Updated FSAR" l Appendix A presents guidance for voluntary efforts that licensees may undertake to improve 1 and simplify their UFSARs to reduce the burden associated with maintaining the information in the UFSAR comp!ste and accurate. This appendix contains guidance consistent with guidance in the staff's proposed generic letter on controlling modifications to the UFSAR, reformatting i
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information in the' UFSAR, simplifying UFSAR information, removing unnecessary information .
- from the UFSAR, and reporting to the NRC the information removed from the UFSAR. ;
- Section A1, " Introduction" l This section notes that the guidance in the appendix is neither required nor necessary for- l compliance with 10 CFR 50.71(e). ;
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Section A2, " Controlling Modifications to the Updated FSAR" i This section contains guidance similar to guidance in the proposed generic letter for making i modifications to the UFSAR. Licensees should develop a process to control the reformatting, !
simplification, and removal of information; ensure that information required to be in a UFSAR is not removed; and inform the NRC of the information removed and the basis for its removal.'
l Section A3, "Refonnetting of Updated FSAR Information" The format of the UFSAR is at the option of the licensee, provided that the content of the i UFSAR is maintained consistent with $50.34(b) and $50.71(e), other regulatory guidance j committed to by the licensee (e.g., Regulatory Guide 1.70), and the guidance in NEl 98-03. i The guidance allows historical information to be annotated as such, or relocated into separate j volumes or appendices. I i
Section A4, " Simplifying Updated FSAR Information" Guidance is presented for removing excessive detail, replacing detailed drawings with simplified schematics, and referencing other documents in UFSARs (including differentiating between general references and material incorporated by reference).
Section AS, " Removing Unnecessaryinformation From Updated FSARs" l Guidance is given for removing obsolete information (e.g., information associated with a system that has been removed from the facility), redundant information, and commitments.
Section A6, " Reporting to the NRC Information Removed From the UFSAR" It is noted that licensees should report to the NRC the information removed from the UFSAR in accordance with Appendix A. This notification should accompany the licensee's periodic update required by 10 CFR 50.71(e).
Proposed Draft Raoulatorv Guide The staff has found the guidance in NEl 98-03, Revision 0, to be acceptable and is proposing to endorse NEl 98-03 in DG-1083 as one acceptable method for complying with 10 CFR 50.71(e).
As noted above, the guidance in NEl 98-03 is generally consistent with the proposed generic letter, and where the guidance differs, the staff finds the altemative proposed by NEl to be acceptable. None of the differences are considered to be major. Therefore, DG-1083 endorses NEl 98-03, Revision 0, without exception.
The draft regulatory guide has six regulatory positions, as follows:
- 1. NEl 98-03 provides methods that are acceptable for complying with the provisions of
$50.71(e).
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- 2. NEl 98-03 references other documents, but the NRC's endorsement of NEl 98-03 !
should not be considered an endorsement of the referenced documents. l
- 3. NEl 98-03 includes examples to supplement the guidance. The examples are illustrative only, and the NRC's endorsement of NEl 98-03 should not be considered a i determination that the examples are applicable for all licensees. Licensees must ensure l that an example is applicable to its particular circumstances before implementing the !
guidance as described in an example.
- 4. NEl 98-03 gives guidance in Section A4.3 on how to maintain and update material !
incorporated by reference into the UFSAR. DG 1083 clarifies this guidance by noting !
that for information to be incorporated by reference, the information must have been l provided to the NRC on the licensee's docket (i.e., publicly available) unless there exists l an explicit NRC requirement to maintain the information on site. Furthermore, ;
information incorporated by reference into the UFSAR is subject to the requirements of 1
$50.71(e) and $50.59 unless separate NRC change control requirements apply (e.g.,
10 CFR 50.54(a)). This clarification could be removed from DG-1083 if NEl 98-03 were revised to incorporate the clarification before publication of the final regulatory guide.
- 5. DG-1083 does not supersede prior commitments made by licensees with respect to their FSARs and, by extension, their UFSARs. This includes commitments to the content and format of the FSAR (e.g., Regulatory Guide 1.70). Therefore, licensees that have committed to the format and content of their UFSAR must continue to meet those commitments, or must modify the previous commitments in acco dance with the licensees' commitment management process.
- 6. Licensees may use other methods than those described in NEl 98-03 to meet the requirements of $50.71(e), but the NRC will determine the acceptability of other methods on a case-by-case basis.
Value-Imoact Statement DG-1083 contains a value-impact statement. In general, the guidance in Section' .3 through 9 i of NEl 98-03 is consistent with prior practice and staff positions, although those staff positions have not been clearly articulated in all cases. Furthermore, the flexibility allowed licensees by Appendix A to NEl 98-03 represents a relaxation from former staff practice. The benefits that a licensee may gain from the approaches in Appendix A are dependent on the extent to which the licensee chooses to implement each specific provision. It is assumed that a licensee will only implement the voluntary provisions to the extent that the value exceeds any associated cost.
The staff position is that the value to individual licensees, the industry, the NRC, and the public that results from complete and accurate UFSARs outweighs the costs to licensees and the NRC that are presently associated with using UFSARs that are incomplete and inaccurate.
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Retention of Information Associated With Risk-Sionificant Structures. Systems. and Components (SSCs) l During its review of NEl 98-03, the staff identified that the voluntary guidance in Appendix A e could be interpreted to allow the removal of all information that is not required to be !
incorporated into a UFSAR, regardless of whether that information is associated with risk- l significant SSCs. The conditions under which this could occur would be for those SSCs that l
are not: (1) addressed by technical specifications, (2) necessary for the facility to meet its :
design basis or safety analyses,-(3) part of the UFSAR Description, as defined in Section 3.7 of ;
NEl 98-03 or (4) otherwise required to be incorporated into the UFSAR in accordance with ;
' $50.34(b), $50.71(e), or other NRC requirements including license conditions and orders. '
The staff's concem is that the removal of this information was not intended by either the staff's proposed generic letter nor NEl 98-03. The staff discussed this concem with NEl in a 1 conference call on December 22,1998. Language such as the following was discussed as a 'l clarification to NEl 98-03, most likely as a fourth bullet in Section A2, " Controlling Modifications I to the Updated FSAR:"
- It is the intent of this guideline to help licensees remove unimportant information from UFSARs such as excessive detail, obsolete, or redundant information. This guideline is not intended to be used to remove information from UFSARs regarding SSCs that insights from operating experience or probabilistic risk assessments would indicate hre risk significant.
While NEl did not commit to make this change until NEl had the opportunity to discuss the clarification with the task force that developed NEl 98-03, NEl did convey that a clarification consistent with the above language would be considered since it appeared to be consistent with the intent of NEl 98-03. However, it should be understood that this limitation is voluntary; 11, a licensee that chose to take out information regarding risk-significant SSCs would be free to do so, absent an order or other legally binding requirement (e.g., a rule) by the Commission to the licensee directin1 the licensee not to remove the information. Such an order or other legally-binding requirer. ent would have to be based on a finding that removal of such information (and by implication the SSCs described) would bear on reasonable assurance of adequate protection.
The staff believes that this concem can be resolved prior to publication of the final regulatory guide. In order to ensure the public is given the full opportunity to comment on the proposed clarification, the staff will specifically request comments on the above language and the appropriateness of retaining information associated with risk-significant SSCs in UFSARs in the Federal Register Notice for DG-1083.
CONCLUSIONS:
The staff has addressed all issues with respect to the guidance in NEl 98-03. Licensees that ;
implement NEl 98-03 can comply with 10 CFR 50.71(e). Appendix A to NEl 98-03 contains j provisions that allow licensees to improve and simplify the content and format of their UFSAR in I a manner that is acceptable to the staff. The staff has developed a draft regulatory guide, DG-i
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The Commissioners 9 1083, that endorses NEl 98-03, without exception, as one acceptable method for complying f with 10 CFR 50.71(e).
RESOURCES:
i The resources necessary to complete these activities related to issuing the regulatory guide are currently budgeted (approximately 2 FTE over two years). No additional staff resources are necessary to issue the draft regulatory guide, address public comments, issue the final regulatory guide, and train the appropriate staff beyond those resources previously identified in SECY-97-205 and SECY 98-087.
COORDINATION:
The Office of the General Counsel has no legal objection to this paper and to publication of the proposed draft regulatory guide for public comment. The Office of the Chief Financial Officer has reviewed this Commission paper for resource implications and has no objections. The Committee to Review Generic Requirements (CRGR) has endorsed the proposed draft regulatory guide. The Advisory Committee on Reactor Safeguards (ACRS) has deferred its ;
review until after the staff addresses the public comments.
j RECOMMENDATIONS: 1 1 1 The staff recommends that the Commission approve
- 1. publication of the draft regulatory guide, DG-1083, for public comment.
- 2. relee.2e of this Commission paper and its attachments to the public document room within five days of its date of issuance. This will provide the NEl task force the opportunity to review the proposed clarification concerning the retention of information associated with risk-significant SSCs at the earliest possible date.
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William D. Travers Executive Director for Operations Attachments:
- 1. Draft Regulatory Guide DG-1083 l
- 2. Revision 0 of NEl 98-03 l l
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i Commissioners' completed vote sheets / comments should be provided directly to i
the Office of the Secretary by COB Thursday, January 21, 1999. :
Commission Staff Office comments, if any, should'be submitted to the P
Commissioners NLT January 13, 1999, with an information copy to the Office l of the Secretary. If the paper is'of such a nature that it requires additional i review and comment, the Commissioners and the Secretariat should be apprised !
of when comments may be expected.
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U.S. NUCLEAR REGULATORY COMMISSION
[ S December 1998 OFFICE OF NUCLEAR REGULATORY RESEARCH 5
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oe DRAFT REGULATORY GUIDE Draft DG-1083
Contact:
T. A. Bergman (301)415-1021 i
DRAFT REGULATORY GUIDE DG-1083 CONTENT OF THE UPDATED FINAL SAFETY ANALYSIS REPORT IN ACCORDANCE WITH 10 CFR 50.71(e)
A. INTRODUCTION in 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities," Section l 50.34, " Contents of Applications: TechnicalInformation," contains requirements for the contents of !
applications for construction permits and operating licenses for nuclear power reactors. An i application for a construction permit must include a preliminary safety analysis report (PSAR) pursuant to 10 CFR 50.34(a). An application for an operating license must include a final safety l analysis report (FSAR)in accordance with 10 CFR 50.34(b). For holders of operating licenses,10 i
CFR 50.71(e) requires updated FSARs' to be developed and periodically updated.
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Guidance for the organization and contents of PSARs and FSARs has existed since June 30, l
1966, when the " Guide to the Organization and Contents of Safety Analysis Reports" was issued.
The most recent guidance document is Revision 3 of Regulatory Guide 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants (LWR Edition)," dated November 1978.
Limited guidance for the format and content of UFSARs was also provided in Generic Letter 80-110,
" Periodic Updating of Final Safety Analysis Reports (FSARs)," dated Dacember 15,1980.
As a result of lessons teamed from the Millstone experience and other initiatives related to UFSARs, the NRC has determined that additional guidance regarding compliance with
'The termirviogy for " updated FSARs* varies throughout the industry. In this guide, the terms updated FSAR, UFSAR, ar4r10SAR (updated Safety Analysis Report) are equivalent and have the same meanings.
This regulatory guide is being assued in draf t form to involve the pubhc in the oorly stages of the development of a regulatory position in this area it has not received complete staff review and does not represent en official NRC staff position.
Public commente are bemg solicited on the draf t guide (including any implementation schedule) and its associated value/ impact statement.
Comments should be accompanied by appropriate supporting data. Written comments may be submitted to the Rules and Directives Branch.
ADM. u.S. Nuclear Regulatory Commission. Washington, DC 20555. Copies of comments received may be examined et the NRC Public Document Room,2120 L Street NW., Washington. DC. Comments will be most helpful if received by Requeste for single copies of draft or active regulatory guides (which may be reproducod) or for piece nent on en automatic distnbution list for single copies of future draf t guidee in specific divisions should be made in writmg to the U.S. Nuclear Regulatory Commission. Washington, DC l 20555. Attention: Reproduction and Distribution Services Section, ar by fax to (3011415 2289, or by email to DISTRIBUTION @NRC. GOV.
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l 10 CFR 50.71(e)is necessary. The staff recommended specific actions in SECY-97-036,
" Millstone Lessons Learned Report, Part 2: Policy issues," dated February 12,1997. In a I staff requirements memorandum dated May 20,1997, the Commission directed the staff, in l
part, to issue guidance for complying with 10 CFR 50.71(e) so that UFSARs are updated to reflect changes to the design bases and to reflect the effects of other analyses performed !
since originallicensing that should have been included under 10 CFR 50.71(e). This regulatory guide provides the guidance requested by the May 20,1997 staff requirements memorandum. -
The information collections contained in this draft regulatory guide are covered by the l requirements of 10 CFR Part 50, which were approved by the Office of Management and i Budget, approval number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB ,
control number.
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B. DISCUSSION OBJECTIVE '
The objectives of 10 CFR 50.71(e) are to ensure that licensees maintain the information in the UFSAR to reflect the current status of the facility and address new issues as they arise, so that the UFSAR can be used as a reference document in safety analyses.
DEVELOPMENT OF INDUSTRY GUIDELINE NEl 98-03 On November 14,1997, the Nuclear Energy Institute (NEI) provided a draft guidance document, " Draft industry Update Guidelines for Final Safety Analysis Reports," to the NRC staff for information. In parallel with industry's efforts, the staff developed a proposed generic letter, " Interim Guidance for Updated Final Safety Analysis Reports in Accordance with 10 CFR 50.71(e)." This proposed generic letter and NEl's draft guideline were provided to the
! Commission in SECY-98-087, dated April 20,1998. In SECY-98-087 the staff recommended that the Commission approve issuance of the proposed generic letter for public comment as interim guidance. The staff proposed to continue to work with NEl to resolve differences between the positions in the proposed generic letter and the draft industry guideline so that the industry guideline could be endorsed in a regulatory guide and thereby serve as permanent guidance for the content of UFSARs.
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I In a staff requirements memorandum dated June 30,1998, the Commission disapproved issuance of the proposed generic letter and directed the staff to attempt to resolve differences between the draft industry guideline and the proposed generic letter so that the i
industry guideline could be endorsed. in an attachment to a meeting summary dated June 15, i
1998, the staff provided initial comments on the draft industry guideline.
NEl submitted a Draft Revision 0 of NEl 98-03, " Guidelines For Updating Final Safet" Analysis Reports," for staff review on July 8,1998. NEl 98-03 was substantially modified ,
from the November 14,1997, draft industry guideline, and it incorporated many of the l
positions of the proposed generic letter and addressed many of the issues raised in the staff's comments provicted on June 15,1998. In a letter dated September 1,1998, the staff !
provided comments on Draft Revision 0 of NEl 98-01. !
NEl submitted the final version of Draft Revision 0 of NEl 98-03 on September 30, 1998. The final draft conformed to the staff's comments or provided alternatives to the staff's proposed resolution of each issue, in a letter dated October 8,1998, the staff provided NEl comments on the final draft. NEl then submitted Revision 0 of NEl 98-03 to the staff for endorsement on November 2,1998.
C. REGULATORY POSITION l
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- 1. NEl 98-03 '
Revision 0 of NEl 98-03, " Guidelines for Updating Final Safety Analysis Reports,"' l dated October 1998, provides methods that are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.71(e).
- 2. OTHER DOCUMENTS REFERENCED IN NEl 98-03 NEl 98-03 references other documents, but NRC's endorsement of NEl 98-03 should not be considered an endorsement of the referenced documents.
'This document is available for inspection or copying for a fee in the NRC Public Document Room, 2120 L Street ;
NW., Washington, DC; the PDR's mailing address is Mail Stop LL-6, Washington, DC 20555; phone (202) 634-3273; fax (202) 634-3343.
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- 3. USE OF EXAMPLES IN NEl 98-03 NEl 98-03 includes examples to supplement the guidance. These examples are illustrative only, and the NRC's endorsement of NEl 98-03 should not be considered a determination that the examples are applicable for alllicensees. A licensee should ensure that an example is applicable to its particular circumstances before implementing the guidance as described in an example.
4, LICENSEES COMMITTED TO REGULATORY GUIDE 1.70 This regulatory guide does not supersede any prior commitments made by licensees with respect to their FSARs (and by extension, their UFSARs), such as Regulatory Guide 1.70 (any revision) or its predecessor guidance documents. Therefore, a licensee that has made such a commitment to updated FSAR format and content must continue to meet this prior commitment, or the commitment should be modified in accordance with the licensee's commitment management process to allow fullimplementation of NEl 98-03,
- 5. INFORMATION INCORPORATED BY REFERENCE NEl 98-03 gives guidance in Section A4.3 on how to maintain and update material
" incorporated by reference." The guidance in Section A4.3 may be unclear as to the reporting and change control processes applicable to material incorporated by reference into l the UFSAR, and the following guidance is provided as a clarification to that in NEl 98-03. ;
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information incorporated by reference into the UFSAR must be provided to the NRC on the licensee's docket (i.e., publicly available) unless there is an explicit NRC requirement that the information is to be maintained on site. Furthermore, information incorporated by i reference into the UFSAR is subject to the requirements of 10 CFR 50.71(e) and 10 CFR 50.59 unless separate NRC change control requirements apply (e.g.,10 CFR 50.54(a)).
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- 6. USE OF OTHER METHODS Licensees may use methods other than those proposed in Revision 0 of NEl 98-03 to meet the requirements of 10 CFR 50.71(e). The NRC will determine the acceptability of other methods on a case by-case basis.
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D. IMPLEMENTATION '
i The purpose of this section is to provide information to applicants and licensees i
regarding the NRC staff's plans for using this regulatory guide.
This draft regulatory guide has been released to encourage public participation in its development. Except in those cases in which an applicant or licensee proposes an acceptable alternative method for complying with specified portions of the NRC's regulations, the methods to be described in the final version of this guide, reflecting public comments, will be used in the evaluation of the effectiveness of the licensee's UFSAR in ;
accordance with 10 CFR 50.71(e).
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VALUEllMPACT STATEMENT All licensees of nuclear power plants are required by 10 CFR 50.71(e) to update their Final Safety Analysis Reports (FSARs). A licensee's FSAR was originally submitted as part of the licensee's application for an operating license, and it must be updated to reflect all the information and analyses submitted to the NRC since the FSAR was originally submitted.
The updated FSAR (UFSAR) is required by 10 CFR 50.71(e) to include the effects of all changes made in the facility or procedures as described in the FSAR, all safety evaluations performed in support of requested license amendments, and all analyses of new safety issues. This regulation,10 CFR 50.71(e),is known as the FSAR Update Rule.
Licensees have not been implementing the FSAR Update Rule uniformly, and there is very little definitive guidance on the implementation of the FSAR Update Rule. Further, NRC staff positions have not been clearly articulated, and the NRC staff has not thoroughly reviewed the periodic updates that have been submitted by licensees.
Since the regulation for updating the FSAR already exists, a regulatory guide is the most effective method to provide guidance to licensees on UFSARs. A NUREG document would not be appropriate as they do not contain regulatory guidance.
The most recent guidance on UFSARs is Revision 3 of Regulatory Guide 1.70,
" Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants (LWR Edition)," which was issued in November 1978. Limited guidance on the format and content of UFSARs was also provided in Generic Letter 80110, "Penodic Updating of Final Safety Analysis Reports (FSARs)," which was dated December 15,1980. The NRC staff prefers to develop a new regulatory guide on UFSARs rather than revise Regulatory Guide 1.70, which deals more with the initial preparation of preliminary and fina! safety analysis reports.
The Nuclear Energy Institute (NEI) has prepared a guidance document, NEl 98-03,
" Guidelines for Updating Final Safety Analysis Reports." The NRC staff has reviewed NEl 98-03 and both NEl and NRC have resolved initial differences over the document. Guidance in NEl 98-03 is organized into two parts: (1) Sections 3 through 9 contain information that is required to be in a UFSAR (in accordance with 10 CFR 50.34(b) and 10 CFR 50.71(e)), and (2) Appendix A contains optional activities that licensees may undertake to improve and simplify the UFSAR (i.e., the guidance in Appendix A to NEl 98-03 is neither required nor necessary for compliance with 10 CFR 50.71(e)). In general, the guidance in Sections 3 6
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through 9 is consistent with past staff practices. The guidance in Appendix A represents a !
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relaxation from prior staff practice in some instances. ;
Appendix A to NEl 98-03 includes guidance for controlling modifications to the UFSAR, including reformatting of information, removing excessive detail, replacing detailed drawings with simplified schematics, referring to other documents and incorporating them
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by reference, removing obsoletw and redundant information, removing commitments, and !
t reporting information removed from the UFSAR to the NRC. Licensees may initiate these voluntary modifications to their UFSARs, unre' ed to plant changes or required updates to their UFSARs, to improve the focus, clarity, and maintainability of the UFSAR. In general, '
this flexibility allowed licensees by NEl 98-03 represents a relaxation from previous staff positions. However, the extent to which a particular licensee may benefit from implementing NEl 98-03 depends upon the extent to which the licensee chooses to i
implement tha provisions in Appendix A to NEl 98-03 that the licensee has determined that '
the value exceeds any associated cost.
The NRC staff position is that the value to individuallicensees, the industry, the NRC, and the public that results from complete and accurate UFSARs outweighs the costs to licensees and the NRC that are presently associated with using UFSARs that are incomplete and in?ccurate. The NRC staff intends to endorse, in a final regulatory guide, the industry's proposed approach, described in NEl 98-03, as one acceptable method for complying with 10 CFR 50.71(e). A draft regulatory guide, DG-1083, " Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e)," should be issued for public com' ment. The final regulatory guide, if issued, will represent a method acceptable to the staff that reflects the industry's preferred approach, as modified by the NRC, to address public comments received on the guidance.
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NU(llAR INERGY [N5iliUTE N W $NYN Y NUCL EAR GENERATON November 2,1998 Mr. Jack Roe Acting Director, Division of Reactor Program Management U.S. Nuclear Regulatory Commission ,
Washington, DC 20555-0001 I PROJECT NUMBER: 689
Dear Mr. Roe:
Enclosed is NEl 98-03, Revision 0, Guidelines for Updating Final Safety Analysis Reports. Consistent with our discussions with the NRC staff and the action plan for close-out of FSAR update issues, we request NRC endorsement of this industry guideline in a regulatory guide as an acceptable approach for compliance with
A pre-publication draft of the industry guidance, reflecting resolution of all remaining NRC comments identified in the staffs October 8 letter, was provided to participants in 3
NEI's recent workshop on licensing issues. The enclosure reflects only minor editorial differences from that pre-publication draft. !
We plan to distribute NEI 98-03, Revision 0, to the industry in the near future. We believe the guidance will provide immediate assistance to continuing licensee efforts }
directed at ensuring the completeness and accuracy of their FSARs consistent with the j requirements of10 CFR 50.71(e). Early application of the guidance will also help identify potential implementation issues warranting follow-up or clarification.
I want to take this opportunity to compliment Frank Akstulewicz and Tom Bergman of the NRC staff for their constructive, safety-focused interactions related to development l of NEI 98-03. Similarly,let me express my appreciation to Dave Matthews, Tom Bergman, Eileen McKenna, and Stu Magruder for their participation in the recent NEI workshop. The feedback from attendees was that the staffs participation contributed greatly to the success of the workshop.
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Mr. Jack Roe .
November 2,1998 Page 2 Ifyou have any questions concerning NEI 98-03, Revision 0, please contact me at 202-739-8081 or Russ Bell at 202-739-8087.
Sincerely, ,
, k-t Anthony h. Pietrangelo Enclosure RJB/ARP/ngs c: Stewart L. Magruder, Jr., NRC l
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NEl 98-03 [ Revision 0) 1 Guidelines for Updating Final Safety Analysis Reports l
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October 1998
NEl 98-03 (Rev. 0)
October 1998 NEl 98-03 [ Revision 0]
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Nuclear Energy Institute Guidelines for Updating Final Safety Analysis Reports 1
l October 1998 Nuclear Energy institute,1776 iStreet N. W., Suite 400, Washington D.C (202.739.8000)
NEI 98-03 (Rev. 0)
October 1998 ACKNOWLEDGMENTS NEl appreciates the invaluable assistance of the FSAR Task Force and Regulatory Process Working Group toward development of this guideline.
NOTICE Neither NEI, nor any ofits employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, methods, or process d:<. losed in this report or that such may not infringe privately owned rights.
NEl 98-03 (Rev. 0)
October 1998 TABLE OF CONTENTS 1 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2 BAC KG ROU N D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3 DEFIN ITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4 ROLE OF THE UPDATED FSAR . . .... . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5 SCOPE OF THE UGATED FSAR ......... ....... ......... .. ....... . .. .... .. ... ..................
6 UPDATING FSARS TO MEET 10 CFR 50.71 (e) ..................................................
7 FREQUENCY OF PERIODIC UPDATES ............................................................. 10 8 TREATMENT OF LONG-TERM TEMPORARY MODIFICATIONS ................................11 9 TREATMENT OF DISCREPANCIES BETWEEN THE FACILITY AND THE UPDATE APPENDIX A: MODIFYING THE UPDATED FSAR APPENDIX B: 10 CFR 50.71 fe) i
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NEl 98 03 (Rev. 0)
October 1998 1 11tTRODUCT10N The purpose of this document is to provide licensees with guidance for updating final safety analysis reports (FSARs) consistent with the requirements of 10 CFR 50.71(e), the FSAR update rule. Guidance is also provided in Appendix A for making voluntary modifications to updated FSARs (UFSARs) (i.e., removal, reformatting and simplification ofinformation, as appropriate) to improve their focus, clarity and maintainability. Figure 1 (page 5) depicts the overall process for updating and modifying the UFSAR.
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2 BACKGROUND l FSARs originally served as the principal reference document in support of Part 50 license applications. The original FSAR described methods for confonning with applicable NRC regulat, ions and contains the technical information required by 10 CFR 50.34(b),
including "information tliat describes the facility, presents the design bases and the limits on its operation, and presents the safety analyses of the structures, systems and components and of the facility as a whole." In 1980, the NRC issued the FSAR update '
rule,10 CFR 50.71(e), which requires licensees to update their FSARs periodically to assure that the information provided is the latest material developed.
Inspections in 1996-97 by the NRC and licensees identified numerous discrepancies between UFSAR ir. formation and the actual plant configuration and operation. These findings have raised questions about possible noncompliance with 10 CFR 50.71(e). The industry has developed this guidance in recognition of the importance of the UFSAR, the need to comply with 10 CFR 50.71(c) update requirements, and the need for UFSARs to be consistent with the plant configuration and operation.
3 DEFINITIONS 3.1 COMMISSION REQUIREMENTS Commission requirements include regulations, license conditions, technical specifications and orders.
3.2 DESIGN BASES Design bases are information that identifies the specific functions to be performed by a structure, system, or component of a facility and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be 1
NEl 98-03 (Rev. 0)
October 1998 (1) restraints derived from generally accepted " state-of-the-art" practices for achieving functional goals or (2) requirements derived from analysis (based on calculations and/or experiments) of the effects of a postulated accident for which a stmeture, system or component must meet its functional goals. (10 CFR 50.2).
Further discussion and examples of design bases are provided in NEl 97-04, Design Bases Program Guidelines.
3.3 HISTORICALINFORMATION Historical information is that which was provided in the original FSAR to meet the requirements of 10 CFR 50.34(b) and meets one or more of the following criteria:
a information that was accurate at the time the plant was originally licensed, but is not intended or expected to be updated for the life of the plant u information that is not affected by changes to the plant or its operation a information that does not change with time.
3.4 OBSOLETE INFORMATION Obsolete information is information about (1) equipment that has been removed from the plant (2) organizations, programs or procedures that are no longer in effect and do not meet the definition of historical infonnation, or (3) design information, evaluations and other UFSAR description that no longer apply to the facility.
3.5 ORIGINAL FSAR The original FSAR is the FSAR submitted with the application for the operating license.
as amended and supplemented, and reviewed by the NRC in granting the initial license to operate the facility. Note that for early licensees, the Final Hazards Summary Report performed the role of the FSAR in the licensing process.
3.6 SAFETY ANALYSES Safety analyses are analyses performed pursuant to Commission requirement to demonstrate the integrity of the reactor coolant pressure boundary, the capability to shut i
down the reactor and maintain it in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the guidelines in 10 CFR 50.34(a)(1) or 10 CFR 100.11 Safety analyses are required to be presented in the UFSAR per 10 CFR 50.34(b) or 10 CFR 50.71(e) and include, but are not limited to, the accident analyses typically presented in Chapter 14 or 15 of the UFSAR.
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4 NEl 98-03 (Rev. 0)
October 1998 3.7 UFSAR DESCRIPTION UFSAR description includes text, tables, diagrams, etc., that provide an understanding of the design bases, safety analyses and facility operation under conditions of normal operation, a,ticipated operational occurrences, design basis accidents, external events, and natural phenomena for which the plant is designed to function.
3.8 UPDATED FSAR The updated FSAR (UFSAR) is the current revision of the FSAR as updated per the requirements of10 CFR 50.71(e).
4 ROLE OF THE UPDATED FSAR UFSA-Rs provide a description of each plant and, per the Supplementary Information for the FSAR update rule, serve as a " reference document to be used for recurring safety analyses perfonned by licensees, the Commission, and other interested parties." The UFSAR is used by the NRC in its regulatory oversight of a nuclear power plant, ,
including its use as a reference for evaluating license amendment requests and in the preparation for and conduct ofinspection activities. For licensees, portions of the UFSAR are used as a reference in evaluating changes to the facility and procedures under j the 10 CFR 50.59 change process. The UFSAR also serves to provide the general public !
a description of the plant and its operation.
5 SCOPE OF THE UPDATED FSAR 10 CFR 50.34(b) defined the scope ofinformation required to be submitted in original FSARs and, by extension, the scope of UFSARs as they exist today. While original FSARs expanded greatly over the years as increasingly detailed infonnation was required ,
of new licensees, the scope given by 10 CFR 50.34(b) provided the common baseline for all original FSARs.
In addition to the scope ofinformation contained in the original FSAR, the scope of today's UFSARs includes information added per the FSAR update rule'. The update rule requires licensees to update their UFSARs to reflect new Commission requirements and the effects of changes to the facility and procedures, safety evaluations and analyses of new safety issues requested by the Cormnission.
! ' The scope of the UFSAR also may be affected by the other NRC requirements, such as 10 CFR 54.21(d). This I
rule requires licensees to supplement their UFSARs as pan of the technical information submitted with license renewal applications.
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NEl 98-03 (Rev. 0)
October 1998 I Just as the scope of the original FSAR was determined by the requirements of 10 CFR i
50.34(b), it follows that the scope ofinformation subsequently added to the original 4 FSAR through the update process should be guided by the requirements used to establish i the content of the original FSAR. ,
t 10 CFR 50.34(b) contains the following statement of general intent conceming the !
required content of FSARs submitted as part of original license applications: 4 The FSAR shall include information that describes the facility, presents i the design bases and the limits on its operation, and presents the safety !
analyses of the structures, systems and components and of the facility as a whole.
Subsections (1) through (9) of 10 CFR 50.34(b) funher define or amplify this statement !
of general intent. Cenain information required to be included in original FSARs is now l controlled in separate licensee documents in accordance with other NRC regulations. For !
example, the plant technical specifications establish the limits on facility operation, !
including safety limits; limiting safety system settings; and limiting conditions for i
operation for structures, systems and components. The technical specifications were j required as part of the original FSAR under 10 CFR 50.34(b)(6)(vi), but are now i controlled separately from the UFSAR per 10 CFR 50.36.
i Based on analysis of 10 CFR 50.34(b), UFSAR updates should contain the followmg basic types ofinformation conceming new requirements and information developed since the UFSAR was last updated that are required to be reflected in the UFSAR under 10 CFR 50.71(c):
3 e new or modified design bases-a summary of new or modified safety analyses i e UFSAR description sufficient to permit understanding of new or modified !
design bases, safety analyses, and facility operation (as defined in Section i 3.7).
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Figure 1 PROCESS FOR UPDATING AND MODIFYING THE UFSAR UFSAR Update Process i UFSAR Modification Process !
(Per 10 CFR 50.71(e)) (See Appendix A) 1 New Requirements.
Plant / Procedure Changes.
input safety Evaluations.
Current UFSAR Content New lasses i V
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v e Apply Apply i Evaluation UFSAR Content i UFSAR Modification Upcate Criteria Guidance e e v Upcate Simplity/Re,nove Reformet UFSAR UFSAR UFSAR informatson Information information Changes w
icentify information Removed and Basis for Removal Submit
!. Reporting UFSAR Update to the NRC 5
NEl 98-03 (Rev. 0)
! October 1998 6
UPDAllNG FSARs TO MEET 10 CFR 50.71(e) ;
1 6.1 WHAT THE REGULATIONS REQUIRE
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10 CFR 50.71(e) requires licensees to periodically update their UFSARs to assure they l
remain up-to-date such that they accurately reflect the plant configuration and operation.
l Per 10 CFR 50.71(c)(4), the UFSAR is required to reflect changes up to a maximum of j
six months prior to the date that the last update was submitted to the NRC. The 10 CFR j
50.71(e) requirements concerning the content of updates are as follows2: !
Each person licensed to operate a nuclear power reactor pursuant to the !
provisions of @ 50.21 or ! 50.22 of this part shall update periodically, as provided in paragraphs (e)(3) and (4) of this section, the final safety analysis report (FSAR) originally submitted as part of the application for the operating license, to assure that the information included in the FSAR contains the latest material developed. This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the licensee or prepared by the licensee pursuant to Commission requirement since the submission of the original FSAR or, as appropriate, the last updated FSAR. The updated 1*: AR shall be revised to include the effects of: all changes made in the facihty or procedures as described in the FSAR; all safety evaluations performed by the licensee either in support of requested license amendments or in support of conclusions that changes did not involve an unreviewed safety question; and all analyses of new safety issues performed by or on behalf of the licensee at Commission request. The updated information shall be appropriately located within the FSAR. ,
The rule does not require that licensees review all the information contained in the UFSAR for each periodic update. Rather, the intent of the mle is that licensees update only those portions that have been affected by licensee activities since the previous update. Per the Supplementary Infonnation provided with the 1980 FSAR update rule, Submittal of updated FSAR pages does not constitute a licensing action buc is only intended to provide information. It is not intended for the purpose of re-reviewing plants.... The material submitted may be reviewed by the NRC staff but will not be formally approved.
The rule specifies the types of new information that must be evaluated to determine if the UFSAR must be updated to reflect the new information, i.e., new requirements, changes to the facility or procedures, including supporting safety evaluations, and NRC requested analyses. The following subsections provide guidance for implementing the
! requirements.
l In addition to the update requirements of 10 CFR 50.71(c), the rule also includes certain administrative and reporting requirements. The full text of 10 CFR 50.71(c) is provided in Appendix B to this report.
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6.1.1 New Regulatory Requirements UFSARs must be updated to reflect changes to the facility resulting from new or amended requirements, e.g., Appendix R, die Station Blackout rule (10 CFR 50.63), the Anticipated Transient Without Scram (Al WS) rule (10 CFR 50.62), or plant-specific orders. As a result of such new requirements, the following information must be incorporated in the UFSAR, as applicaNe-a new or modified design bases a summary of new or modified safety analyses e
appropriate UFSAR description as defined in Section 3.7 of this guideline.
If a new NRC requirement does not result in these types ofinformation, the UFSAR does not need to be updated to reflect the new requirement.
6.1.2 Changes to the Facility or Procedures The UFSAR must be updated to reflect the following effects, as applicable, of changes implemented under 10 CFR 50.90 or 10 CFR 50.59, including supporting safety evaluations:
a a change requires update of the existing UFSAR information, including changes to existing design bases, safety analyses or description of existing structures, systems, components or functions described in the UFSAR m a change results in the removal frem the plant of SSCs described in the UFS A R or the elimination of functions or procedures described in the UFSAR a
a change or supporting safety evaluation results in new design bases or safety analyses, or associated description. that must be included in the UFSAR.
If a change or supporting safety evaluation does not affect existing UFSAR information and does not result in new design bases, safety analyses or UFSAR description, the UFSAR does not need to be updated to reflect the change.
6.1.3 Analyses of New Safety Issues Licensees should evaluate 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 reflectea in UFSAR updates only if, on the basis of the results of the requested analysis or evaluation, the licensee determines that the existing design bases, safety analyses or UFSAR description are either not 7
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October 1998 accurate or not bounding or both. . The existing design bases, safety analyses and UFSAR ,
description must be updated to reflect the new information, as appropriate.
i If the NRC-requested analyses or evaluations do not cause any of these effects, no change l to the UFSAR is required. !
6.1.4 Update Process Considerations Licensees should establish a process to identify the types ofnew information that must be evaluated to determine if the UFSAR must be updated to reflect the new information. To be consistent with the requirements of the FSAR update rule, the process should include l
sufficient administrative controls to identify information and analyses submitted pursuant to Commission requirements; changes to the facility or procedures; safety evaluations .
and analyses of new safety issues performed at Commission request. l In general, controls sufficient to identify information pursuant to Commission i requirement should focus on changes to NRC regulations, license conditions, orders and technical specifications. The controls for identifying changes to the facility or procedures and safety evaluations should be integrated with existing licensee administrative controls i for implementing design and procedure changes, including the process used by licensees i in preparing, reviewing and approving 10 CFR 50.59 evaluations. The controls for identifying analyses of new safety issues performed at. Commission request should focus ,
on NRC bulletins, generic letters and analogous plant-specific communications, including j NRC requests pursuant to 10 CFR 50.54(f).
6.2 LEVEL OF DETAIL FOR FSAR UPDATES While not explicitly addressing the level of detail required for FSARs,10 CFR 50.34(b)(2) required that original FSARs include:
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... description and analysis of the structures, systems, and components of the facility, with emphasis upon performance rec uirements, the bases, with technical justification therefor, upon, which suci requirements have been
. established, and the evaluations required to show that safety functions will be accomplished. . The description shall be sufficient to permit understanding of the system designs and their relationship to safety !
evaluations.
1 In addition, the Supplementary Information provided with the 1980 FSAR update rule stated: "The level of detail to be maintained in the UFSAR should be at least the same as originally provided." Thus, existing UFSAR information of a similar nature may provide {
a guide for determining the level of detail for new information to be included in UFSAR l updates. However, the primary consideration in determining the level of detail for new l
information is whether updated information is sufficient to permit understanding of new !
or modified safety analyses, design bases and facility operation.
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The following examples illustrate the application of the UFSAR update guidance.
CASE 1: The licensee action is not in response to a new Commission requirement, doe' not involve a change, safety evaluation or analysis of a new issue, and does not affect '
existing UFSAR information. Therefore, no update to the UFSAR is required by 10 C 50.71(c). i Examnle I- Generi~. Letter %-01, " Testing of Safety-Related Circuits," requested licensees to I l conduct a review of Logic System Testing to ensure that all elements of the logic '
circuits were being adequately tested and met the technical specification surveillance requirement for adequate logic system functional testing. ;
This generic correspondence did not constitute a new regulatory requirement and j did not request a new analysis. Provided the licensee response to Generic Letter '
< 96-01 did not result in a change to the facility or actions that affected existing UFSAR information, no change to the UFSAR is required. '
CASF 2: The licensee action responds to a new Commission requirement or involves a change, safety evaluation or analysis of a new issue, and update of the UFSAR is required to change existing information.
Examole I i
i A change to the safety injection system was initiated to address an operability -
concem identified in NRC Bulletin 88-04, " Potential for Safety-Related Pump Loss." An evaluation of safety injection pump minimum flow lines resulted in an increase in the recommended minimum-flow rate to preclude hydraulic instability at low flow conditions and assure pump operability. As a result of this evaluation, the orifices in the safety injection recirculation lines were modified to provide for increased minimum-flow rate for the pumps.
Unlike the generic letter in the example of Case 1, NRC Bulletin 88-04 requested that licensees evaluate safety-related pump performance under minimum flow conditions, and the licensee evaluation resulted in a change to the safety injection recirculation lines. Because sufficient minimum-flow is necessary to ensure the j
system is able to perform its intended safety function, the UFSAR description i associated with the safety injection system should be modified to include a discussion of the minimum-flow function as it relates to maintaining operability
- of the safety injection pumps. In some cases, this may entail adding UFSAR discussion of the minimum-flow function where none previously existed.
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October 1998 Iflicensee evaluations requested by Bulletin 88-04 determined the existing minimum-flow design to be acceptable, no change to the UFSAR is required.
CASE 3: The licensee action responds to a new Commission requirement or involves a change, safety evaluation or analysis of a new issue, and update of the UFSAR is required to reflect new information.
Examote 10 CFR 50.62 (the ATWS rule) required the installation of a new mitigation system specific to the type of plant (Westinghouse, Combustion Engineering, etc.). In response to the ATWS rule, the licensee installed new equipment in the facility. An evaluation was performed in accordance with the guidance in Section 6 to determine if update of the UFSAR was required. Because ATWS i constitutes new Commission requirements for the plant, the design bases and associated description of the new ATWS equipment should be added to the UFSAR.
CASE 4: The licensee action responds to a new Commission requirement or involves a change, safety evaluation or analysis of a new issue, and update of the UFSAR is not required.
Examole The NRC issued a new requirement,10 CFR Part 26, requiring licensees to implement a Fitness for Duty Program (FFD). An evaluation was performed in accordance with the guidance in Section 6 to determine if update of the UFSAR was required. The FFD program did not result in new or modified safety analyses or design bases. Provided that the UFSAR does not contain security-related information affected by FFD program implementation, no change or addition to the UFSAR is required as a result of the new requirement.
7 FREQUENCY OF REQUIRED UPDATES As required by 10 CFR 50.71(e)(4), licensees are required to submit a periodic UFSAR update annually or within six months after each refueling outage provided the inten al between successive updates does not exceed 24 months. Licensees may request an exemption from this requirement from the NRC. For example, the NRC has granted exempt' ions allowing licensees to submit a single, combined periodic update for multi-unit plants.
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October 1998 i
8 TREATMENT OF LONG-TERM TEMPORARY MODIFICAT10llS i The UFSAR is intended to be consistent with the plant configuration and operation.
Nevenheless, at any given time there may be a number of temporary plant and/or procedure changes in effect to suppon corrective action, maintenance or other plant activity. Temporary changes in suppon of plant operations should be restored to the normal plant condition, e.g., consistent with the UFSAR, in a timely manner. For temporary conditions involving safety-related equipment, timely restoration is required by 10 CFR 50, Appendix B. Per Generic Letter 91-18, Revision 1, temporary conditions subject to Appendix B that exist longer than the next refueling outage are to be explicitly
' justified as part of tracking documentation.
I Temporary changes generally should not be reflected in UFSAR updates. Because UFSAR information may lag the current plant status by 18-24 months, the UFSAR is an l inefficient vehicle for documenting temporary conditions. This would cause licensees to needlessly revise information in the USSAR that would shonly revert to its prior condition. The result would be a UFSAR that described temporary modifications that are no longer installed, and the UFSAR would not reflect their removal until the next periodic update.
Temporary changes are administratively controlled separately from the UFSAR, and the current status of each is tracked to completion. Tracking documentation ensures that l plant staff can determine the current plant status to suppon ongoing plant operations, l including evaluations performed under 10 CFR 50.59. For temporary changes subject to
! 10 CFR 50.59, evaluations are performed and submitted to the NRC in accordance with l 10 CFR 50.59(b).
In general, UFSM.s should not duplicate the licensee's tracking and reponing of I temporary changes. However, the licensee should reflect in periodic UFSAR updates temporary modifications meeting both of the following criteria: l l
m The temporary modification is expected to be in place throughout the next required periodic UFSAR update cycle', or no schedule for removal has been established; and j m The licensee determines based on the apdce guidance in Section 6 that the temporary modification should be reflected in the next required UFSAR update.
Temporary modifications reflected in the UFSAR should be clearly identified as such to distinguish temporary conditions from the permanent plant configuration. Consistent 2
A periodic update cycle is the period between the cutoff dates for new information for successive required UFSAR updates, i.e., from six months (maximum) prior to submittal of one update until six months (maximum) prior to the next.
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NEl 98-03 (Rev. 0)
October 1998 with licensee configuration control procedures, there may be temporary modifications reflected in the UFSAR that are not reflected in other permanent plant documentation.
If corrective action or other work associated with a temporary modification results in a permanent change to the plant as described in the UFSAR, the UFSAR should be updated to reflect the change.
i Examoles .
1.
~A temporary modification was installed for six months to defeat an alarm that is ,
explicitly discussed in the UFSAR. While the temporary modification affected information contained in the UFSAR, it would not be included in the periodic i update because the alarm is expected to be restored to service before the end of the next required periodic UFSAR upds.te cycle.
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Temporary cables for an intercom system have been routed through one of the i safety-related battery rooms, and the permanent installation is uot planned for more than two years. Based on this schedule, and the schedule for the next UFSAR update, the temporary modification is expected to be in place una after the next UFSAR update cycle. Therefore, the temporary modification should be evaluated per Section 6 of the guideline for inclusion in the next required UFSAR l update. Because the modification does not affect existing UFSAR information, and does not result in new safety analyses, design bases or UFSAR description, j this modification would not be reflected in the next required UFSAR update. !
- 3. i A temporary modification was installed for a safety injection accumulator makeup i water pump, and the permanent resolution of the issue will not be implemented j for at least two more years. Based on this schedule, and the schedule for the next UFSAR update, the temporary modification is expected to be in place until after i the next UFSAR update cycle and should be evaluated per Section 6 of the guidance for inclusion in the next required update. Because the modification i
affects the existing description of the makeup function for the safety injection !
accumulators, the UFSAR should be modified to reflect the temporary i modification as part of the next required update. 4 E
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9 TREATMENT OF DISCREPANCIES BETWEEN THE FACILITY AND THE UP If the licensee discovers a discrepancy between the facility and its description in the l UFSAR, the licensee should address the discrepancy in accordance with its corrective l actions program under 10 CFR 50, Appendix B. Ifevaluation of the discrepancy results i
in the identification of a nonconforming or degraded plant condition that may impact the operability of the associated structures, systems and components, the nonconforming or degraded condition should be addressed in accordance with Generic Letter 91-18, Revision l'.
If evaluation of the discrepancy determines that the UFSAR is incorrect, a correction l should be initiated in accordance with licensee procedures for inclusion in the next UFSAR update.
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d Licensees also should evaluate nonconforming or degraded conditions for reportability pursuant to NRC requirements.
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- I APPENDIK A: MODIFYING THE UPDATED FSAR A1 INTRODUCTION As discussed in this guideline,10 CFR 50.71(e) requires that changes and certain new information be incorporated in periodic updates to the UFSAR. As provided in this ;
appendix, the licensee also may initiate voluntary modifications to the UFSAR- ;
unrelated to plant changes or required updates under 10 CFR 50.71(e)-to improve its focus, clarity and maintainability. The following sections provide guidance for reformatting, simplifying and removing existing UFSAR information. While not discussed in this document, licensees also may add information that goes beyond regulatory requirements and guidance to facilitate use of the UFSAR by plant staff or for other purposes. !
i A2 CONTROLLING MODIFICATIONS TO THE UPDATED FSAR As discussed in the following sections, three types of modifications may be made to the information in the UFSAR: refonnatting, simplification and removal. UFSAR modifications discussed in Sections A3 through A5 that are not the result of changes to the plant or procedures do not require evaluation under 10 CFR 50.59, but they should be administratively controlled through a process that has the following attributes:
a The licensee process controls what and how information is reformatted, simplified or removed from the UFSAR.
m The licensee process ensures that the UFSAR continues to contain the necessary scope ofinformation as discussed in Section 5 of this guideline.
m As discussed in Section A6, the NRC should be informed ofinformation removed from the UFSAR and the basis for the licensee's determination that such information may be removed. This information should be specifically identified to the NRC as part of required UFSAR updates, i.e., in addition to the changed pages and a list of i effective pages currently required by 10 CFR 50.71(e). l
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A3 REFORMATTING OF UPDATED FSAR INFORMATION Neither 10 CFR 50.34(b) nor 10 CFR 50.71(e) contain requirements on the format of l
FSARs. Thus the format of the UFSAR is at the option of the licensee, and the licensee may change the format of the UFSAR provided the content of the UFSAR is maintained consistent with these regulations, regulatory guidance committed to by the licensee (e.g., I Regulatory Guide 1.70), and this guideline. For example, a licensee may elect to !
reformat the UFSAR to more clearly identify the design bases as defined in 10 CFR 50.2.
Appendix A Page1
NEl 98-03 (Rev. 0)
October 1998 Historical information provided in the original FSAR may have become out-of-date and is not expected to be used to support current or future plant operations or regulatory activities. Accordingly, it may be appropriate to reformat such information to distinguish it from UFSAR information actively maintained by licensees to describe the outdated plant configuration and operation.
By definition, reformatting UFSAR information-such as designating certain information as historical or relocating historical information to an appendix-does not remove that information from the UFSAR. As such, changes the licensee initiates to historical information constitute changes to the UFSAR that must be reported to the NRC per 10 CFR 50.71(e).
Absent an NRC requirement, licensees need not update historical infannation in UFSARs to reflect minor changes in population data or other such changes in the site environment.
However, licensees should evaluate potentially significant changes in the site environs, e.g., a new natural gas line within the site boundary or a major new industrial facility near the plant site, to determine if notification of NRC and appropriate update of the UFSAR are required. For example,10 CFR 50.9 requires licensees to " notify the Commission of information identified by the applicant or licensee as having for the regulated activity a significant implication for public health and safety or common defense and security."
Because changes to historical infonnation as defined in this guideline are generally not expected or required (except possibly to reflect a significant change in the site environs, as discussed above), licensee update of such information under 10 CFR 50.71(e) is not expected.
i The following are examples of historical information:
a description of pre-service inspections a description of preoperational tests a description of start-up tests a description of station organization for initial licensing l m comparative plant data provided to support original plant licensing
! a industry or other data obtained to support or develop the original plant design bases,
- including that relating to natural or man-made phenomena such as geography, meteorology, hydrology, geology, seismology, population density and nearby facilities (typically in Chapter 2 of the UFSAR)5 m
lists of references, figures and submittals relevant only to the original licensing proceeding a description of original factory testing of plant equipment, e.g., emergency diesel generators.
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' While data and information supporting the original plant design bases for natural and man-made phenome be designated as historical, the associated design bases themselves should not. This is because the original designj bases continue to be part of the overall design bases for the facility, and new information may warrant their update.
Appendix A Page 2
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NEl 98-03 (Rev. 0)
October 1998 Licensees may reformat such historical infonnation by either of the following, or equivalent, methods: ;
s Qualifying information may be designated as historical via clear annotation in the UFSAR. !
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m Historical infonnation may be relocated to separate volumes or to specially designated appendices of the UFSAR. !
Reformatting of UFSAR information should be controlled in accordance with Section A2.
A4 SIMPljFYlllG UPDATED FSAR IIIFORMAT10ll Licensees may elect to simplify information contained in the UFSAR to improve its focus, clarity and maintainability. As discussed in the subsections below, licensees may simplify UFSAR information by removing excessive detail and by using references to other documents where appropriate.
A4.1 REMOVING EXCESSIVE DETAIL UFSARs contain the scope ofinformation required for the original FSAR by 10 CFR 50.34(b) and the additions to that scope required by 10 CFR 50.71(e). Later license applicants included significantly more detailed infonnation in original FSARs than did earlier applicants. More recent FSARs grew to be 20 to 30+ volumes and may include more detail in cenain respects than was absolutely necessary to support NRC safety and licensing reviews.
Removal of excessively detailed text and drawings can improve the focus of UFSARs on significant descriptive, design bases, operational and analytical information that is relevant and useful to support current and future operational and regulatory activities.
Detailed text and drawings may be removed from the UFSAR to the extent that the information provided exceeds that necessary to present the plant design bases, safety analyses and appropriate UFSAR description.
The following types of excessively detailed textual infonnation may be removed from UFSARs, except as indicated by applicable regulatory guidance or NRC Safety Evaluation Reports:
a descriptive information that is not imponant to providing an understanding of the plant's configuration and operation from either a general or system functional perspective, e.g., component model numbers a design infonnation that is not important to the description of the facility or presentation ofits safety analysis and design bases as defined in 10 CFR 50.2, Appendix A Page 3
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October 1998 l
e.g., component details such as specific motor horsepower ratings that merely l
implement the stated design bases to provide sufficient horsepower to open an !
MOV under differential pressure conditions determined using a specified !
methodology '
a design information that, if changed during the life of the plant, would have no
[
impact on the ability of plant systems, structures and components described in !
the UFSAR to perform their design basis function (s), e.g., specific HVAC !
equipment capacity and flow rate information for structures that do not !
contain equipment that performs design basis functions :
e analytical information, e.g., detailed calculations, that is not imponant to 5 providing an understanding of the safety analysis methodology, input t assumptions and results, and/or compliance with relevant regulatory and industry standards.
Removal of excessively detailed information from the UFSAR should be controlled in f
accordance with Section A2, including reporting to NRC as discussed in Section A6. i i
A4.2 REPLACING DETAILED DRAWINGS WITH SIMPLIFIED SCHEMATICS i Detailed drawings, such as piping and instrumentation diagrams (P& ids), typically contain engineering and component information that goes beyond that appropriate to
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l complement the textual descriptions in the UFSAR and beyond that necessary to aid m -
l understanding of the system design and principal functions. Examples of such ,
information contained in detailed drawings include pipe line numbers, vents and drains, i etc. !
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Simplified schematics may be substituted for detailed drawings under either of the 1 following conditions: (1) the original FSAR contained simplified schematics that the '
- licensee had later replaced with P& ids or other detailed drawings as a matter of j j convenience, or (2) the original FSAR included detailed drawings, but simplified '
schematics will be substituted such that they will not result in removal ofinformation ,
required to be in the UFSAR. !
In the first case, licensees may substitute simplified schematics for detailed drawings ;
because simplified schematics were provided in the original FSAR. Retuming simplified I schematics to the UFSAR would be consistent with the intent of the FSAR update rule {
! that the level of detail of the UFSAR should be at least the same as that provided in the
{ original FSAR. >
4 In the second case, the licensee would need to ensure that simplified drawings together L with associated UFSAR text continue to provide sufficient understanding of design bases,
! safety analyses and facility operation. For example, if the licensee detennines that design bases or safety analyses information is contained in detailed drawings that is not 4
Appendix A Page 4
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- october 1998 !
conveyed by text, tables or other means in the UFSAR, the licensee should incorporate i the information into the simplified schematic or other UFSAR information so that the UFSAR continues to contain all necessary information. Substitution for detailed drawings as described in this f=.gr.ph should be controlled in accordance with j l
' Section A2, including reporting to NRC as discussed in Section A6. '
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A4.3 REFERENCING OTHER DOCUMENTS IN UPDATED FSARs When assessing the presentation of existing UFSAR information (or evaluating information to be added), there may be instances when the infonnation exists in a l i separate source document and it is preferable to reference, rather than duplicate, all or part of the source document in the UFSAR. Referencing, rather than duplicating, information in the UFSAR can simplify the presentation and maintenance of U: SAR information and. in some cases, avoid the need for duplicative reporting of changes to the NRC.
l There are two basic ways licensees can reference other documents in the UFSAR depending on the nature of the document and the purpose of the reference. Each is discussed below.
i GeneralReferences. General references are not considered pan of the UFSAR, but are l
intended to provide background information or additional detail that the reader may refer to in order to leam more about panicular material presented in the UFSAR. These may be texts, environmental studies or technical repons, as well as licensee-controlled documents such as operating or maintenance procedures, calculation manuals, etc.
References to such information may be located at specific points in the UFSAR, or they may be listed at the end of UFSAR chapters or in introductory sections.
Licensees may wish to remove excessively detailed, duplicate UFSAR information that is controlled in a separate licensee source document. In some cases, it may be appropriate to provide a brief summary of the detail being removed and/or a general reference to the controlling document as an aid to the reader. Unless the referenced source ~ document is
" incorporated by reference" (as discussed below), referenced information is not pan of '
t the UFSAR and would not be subject to 10 CFR 50.71(c), except as specifically l committed to by licensees. Replacement of detailed information with a brief summary and/or reference constitutes removal of UFSAR information that must be controlled consistent with guidance in Section A2 and reponed to NRC as discussed in Section A6.
!' Incorperstian by Reference. " Incorporation by reference" refers to a method by which
! all or part of a separate source document can be made pan of the UFSAR without i
" duplicating the desired information in the UFSAR. Information that is appropriate to include in the UFSAR that is also part of a separate licensee-controlled document or technical report may be incorporated in the UFSAR by appropriate reference to that Appendix A Page 5
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l NEI 98-03 (Rev. 0)
October 1998 information. By relying on information " incorporated by reference," licensees may simplify their UFSARs by removing information that is duplicated in separate, controlling program documents such as the Emergency Plan, Offsite Dose Calculation Manual, Fire Protection Plan and Fire Hazards Analysis Report, Technical Requirements Manual, Security Plan Environmental Protection Plan and Quality Assurance Plan.
Considerations when incorporating by reference include the following:
a Licensees should clearly identify in the UFSAR text the document or portion thereof to be incorporated, and state that the document or ponion thereofis " incorporated by reference"in the UFSAR. For example, one option would be to locate in Chapter One of the UFSAR a single section or table that maintains the list of all documents considered incorporated. References should be as clear and specific as possible to avoid misunderstandings about the extent ofinformation incorporated by reference and thus considered part of the UFSAR.
m For a document to be incorporated by reference, the document must meet applicable NRC requirements concerning its availability. For example, some documents are required to be submitted on the docket to the NRC, while others are required to be available on site.
m Information " incorporated by reference" must be maintained and updated in accordance with requirements applicable to the referenced documents. Documents that are not subject to specific update and reporting requirements should be . i maintained in accordance with licensee procedures and be available on site.
AS REMOVING UNNECESSARY INFORMATION FROM UPDATED FSARs :
Licensees may remove obsolete and redundant information and commitments from UFSARs. When removing information as described in this section, licensees should >
follow the guidance in Section A2 for controlling modifications to the UFSAR and Section A6 for reporting to the NRC.
Obsolete Information. Licensees should remove UFSAR information, as appropriate, in connection with removal of SSCs from the plant or elimination of functions or procedures described in the UFSAR. However, licensee review of UFSAR information may identify where this has not occurred, or where removal of UFSAR information in connection with a change was incomplete. In general, licensees should remove from UFSARs description of equipment that is no longer installed in the plant; organizations, programs or procedures that are no longer in effect; and design information, evaluations or other description that no longer apply to the facility. The exception to this guidance is that programmatic information that was explicitly required under 10 CFR 50.34(b) to be included in original FSARs, e.g.. plans for preoperational testing and initial operations,
! may not be removed from the UFSAR. Such information is considered historical; Appendix A Page 6
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licensees may opt to reformat this information in accordance with Section A3.
Where the presence of obsolete infonnation indicates a discrepancy between the UFSAR j and the actual plant configuration or operation, the discrepancy should be evaluated in
. accordance with Section 9 of this guideline.
i Organizations, programs and procedures no longer in effect are considered obsolete, as opposed to historical, if they were instituted and included in the UFSAR subsequent to initial plant licensing.
if equipment has been retired in place (equipment that is no longer in service but has not been physically removed from the plant), functional descriptions in the UFSAR that no longer apply to the equipment are considered obsolete information. To accurately reflect
. the condition of the plant, physical descriptions of equipment retired in place (e.g.,
component and location) in the form of text and/or drawings should be retained in the UFSAR. .
Redundant Information., Licensees may remove duplicate information from the UFSAR. If some or all of the duplicated information is important to facilitate understanding of multiple sections of the UFSAR, the licensee should retain appropriate duplicate information where it is needed. Alternatively, the licensee may remove duplicate information and provide a reference to the location in the UFSAR where the information is to be retained.
l Commitments. Some licensees may have incorporated specific commitments made to the NRC within the UFSAR. Consistent with Commission guidance', where licensees identify information in the UFSAR that constitutes an NRC commitment (as discussed in NEl's Guidelinefor Managing NRC Commitments), these NRC commitments may be l removed from the UFSAR. When removing commitments from the UFSAR, licensees j
must ensure that no information is removed that is required to be in the UFSAR, i.e.,
design bases, safety analyses and associated description.
- Licensees should ensure that NRC commitments removed from the UFSAR are included in licensee commitment management programs as appropriate. If the licensee committed to the NRC to incorporate a commitment in the UFSAR, then the licensee should inform the NRC ofits removal from the UFSAR, consistent with the licensee's commitment change process. ,
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- In a Staff Requirements Memorandum dated May 20.1997, the Commission directed the NRC staff to formulate i
- . an approach to FSAR updates that would " allow obsolete or less meaningful information and commitments to be readily removed from the FSAR.
i Appendix A )
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a NEI 98-03 (Rev. 0)
October 1998 A6 REPORTING TO THE NRC INFORMATION REMOVED FROM THE UFSAR Information removed from the UFSAR should be specifically identified to the NRC as part of required UFSAR updates. A brief description of the information removed and the basis for its removal should be provided. This information should not be incorporated in the UFSAR but should be provided in addition to the changed pages and a list of effective pages currently required by 10 CFR 50.71(c).
The following are examples of description suitable for notifying the NRC that information was removed from the UFSAR:
a removed model number information for components of the Reactor Equipment Cooling System previously contained in UFSAR Section XYZ on the basis that this was excessively detailed information a
replaced the P&lD for the auxiliary feedwater system with a simplified schematic.
I Appendix A i
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, NEI 98-03 (Rev. 0)
- October 1998 APPENDIX B: 10 CFR 50.71 fe) i L i 10 CFR 50.71(e) '
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Each person licensed to operate a nuclear power reactor pursuant to the provisions of f 50.21 or 9 50.22 of this part shali update periodically, as provided in paragraphs (e)(3) and (4) of this section, the final safety analysis report (FSAR) originally submitted as part of the application for the operating license, to assure that the information included
. in the FSAR contains the latest material developed. This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the licensee or prepared by the licensee pursuant to Commission requirement since the submission of the original FSAR or, as appropriate, the last updated FSAR. The updated FSAR shall be revised to include the effects of: all changes made in the facility or procedures as described in the FSAR; all safety evaluations performed by the licensee either in support of requested license amendments or in support of conclusions.that changes did not involve an unreviewed safety question; and all analyses of new safety issues performed by or on behalf of the licensee at Commission -
request. The updated information shall be appropriately located within the FSAR.
(1) The licensee shall submit revisions containing updated information to the Commission, as specified in 6 50.4, on a replacement-page basis that is accompanied by a list which identifies the current pages of the FSAR following page replacement.
(2) The submittal shall include (i) a certification by a duly authorized officer of the licensee that either the information accurately presents changes made since the previous submittal, necessary to reflect information and analyses submitted to the Commission or prepared pursuant to Commission requirement, or that no such changes were made; and (ii) an identification of changes made under the provisions of 9 50.59 but not previously submitted to the Commission.
(3) (i) A revision of the original FSAR containing those original pages that are still applicable plus new replacement pages shall be filed within 24 months of either July 22,1980, or the date of issuance of the operating license, whichever is later, and shall bring the FSAR up to date as of a maximum of 6 months prior to the date of filing the revision.
(ii) Not less than 15 days before $50.71(e) becomes effective, the Director of the Office of Nuclear Reactor Regulation shall notify by letter the licensees of those nuclear power plants initially subject to the NRC's systematic evaluation program that they need not comply with the provisions of this section while the program is being conducted 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 when the systematic evaluation program has been completed. Within 24 months after receipt of Appendix B Page1
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October 1998 ,
this notification, the licensee shall file a complete FSAR which is up to date as of a maximum of 6 months prior to the date of filing the revision.
(4) Subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months.
The revisions must reflect all changes up to a maximum of 6 months prior to the date of
, filling. For nuclear power reactor facilities that have submitted the certifications required by @50.82(a)(1), subsequent revisions must be filed every 24 months.
(5) Each replacement page shall include both a change indicator for the area changed, e.g., a bold line vertically drawn in the margin adjacent to the portion actually j changed, and a page change identification (date of change or change number or both).
(6) The updated FSAR shall be retained by the licensee until the Commission terminates their license. I t
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