ML20204E655
| ML20204E655 | |
| Person / Time | |
|---|---|
| Issue date: | 03/04/1999 |
| From: | Matthews D NRC (Affiliation Not Assigned) |
| To: | NRC |
| References | |
| RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-*****, TASK-DG-1083, TASK-RE NUDOCS 9903250093 | |
| Download: ML20204E655 (8) | |
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DG-1083 March 1999 March 4,1999 l
TO:
DISTRIBUTION LIST FOR DIVISION 1 REGULATORY GUIDES
SUBJECT:
DRAFT REGULATORY GUIDE DG-1083, " CONTENT OF THE UPDATED FINAL SAFETY ANALYSIS REPORT IN ACCORDANCE WITH 10 CFR 50.71(e)"
This proposed Draft Regulatory Guide DG-1083, " Content of the Updated Final Safety Analysis Report,"is being developed to describe methods acceptable to the NRC staff for complying with the Commission's regulations with regard to updating the content of Final Safoty Analysis Reports (FSARs) pursuant to 10 CFR 50.71(e). In addition to comments on DG-1083, the staff would welcome specific comments on the following subject.
During its review of the Nuclear Energy Institute's (NEl's) NEl 98-03, " Guidelines for Updating Final Safety Analysis Reports" (October 1998), the staff noticed that the voluntary guidance in Appendix A to NEl 98-03 could be interpreted to allow the removal of all information that is not required to be incorporated into an updated FSAR (UFSAR),
O regardless of whether that information is associated with risk-significant structures, systems, and components (SSCs). This could occur for SSCs that 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 10 CFR f
50.34(b),10 CFR 50.71(e), or other NRC requirements including license conditions and i
orders.
The staff's concern is that the removal of th:s information was intended by neither the proposed generic letter nor NEl 98-03. The staff is proposing that language to the effect of the following be incorporated into Appendix A of NEl 98-03, most likely as a fourth bullet in Section A2, " Controlling Modifications to the Updated FSAR."
It is the intent of this guideline to help licensees remove unimportant information from UFSARs such as excessive detail, obsolete information, 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 are risk I
significant.
It should be understood that this limitation is voluntary;i.e., licensees who choose 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) directing the licensee not to rer ove the p
information.
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2 WR 041999 Comments should be submitted to the Chief, Rules and Directives Branch, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555. Comments may also be provided via the NRC's interactive rulemaking web site,
<http://RULEFORUM.LLNL. GOV > by following the path for current rulemakings. At this site, comments may be uploaded as files (any format)if your web browser supports that function. For i.1 formation 'about the interactive rulemaking website, contact Ms. Carol Gallagher, (301) 415 5905; e-mail CAG@nrc.oov.
The public comment period for the draft regulatory guide ends on April 30,1999.
Comments received after that date will be considered if it is practical to do so, but assurance of consideration cannot be given for late comments.
David B. Matthews, Direct Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation O
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U.S. NUCLEAR REGULATORY COMMISSION March 1999
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OFFICE OF NUCLEAR REGULATORY RESEARCH Division 1 5
Draft DG-1083
%,o**L DRAFT REGULATORY GUIDE
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Contact:
T.A. Bergman (301)415-1021
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i DRAFT REGULATORY GUIDE DG-1083 l
CONTENT OF THE UPDATED FINAL SAFETY ANALYSIS REPORT IN ACCORDANCE WITH 10 CFR 50.71(e)>
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4 A. INTRODUCTION kb in 10 CFR Part 50, " Domestic Licensing of Production and Utilizatioi) Facilities," Section l
50.34, " Contents of Applications: Technical information," coritainfregiAremerits for the contents of applications for construction permits and operating licenses for'nucleEr power reactors. An application for a construction permit must include a preliminaly,s5f$ty analysis report (PSAR) pursuant to 10 CFR 50.34(a). An application for an c$eratMg license must include a final safety analysis report (FSAR)in accordance with 10 CFR 50.34(b)SFor holders of operating licenses,10 CFR 50.71(e) requ:*es updated FSARs' to be dodeloped hnd periodically updated.
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Guidance fer the organization and contents of PSARs and FSARs has existed since June 30,
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1966, when the " Guide to the Organizati6n'and' Contents of Safety Analysis Reports" was issued.
The most recent guidance document is*Nevistsn 3'of Regulatory Guide 1.70, " Standard Format and Content of Safety Analysis Reports for"Nuclesi Power Plants (LWR Edition)," dated November 1978, l
Limited guidance for the 'ormat ordconferit'of UFSARs was also provided in Generic Letter 80-110,
" Periodic Updating of Final SafekAnalysis Reports (FSARs)," dated December 15,1980.
1 999 As a result of lessons leamed from the Millstone experience and other initiatives related to UFARs, the NRCyas, determined that additional guidance regarding compliance with 10 CFR 50.71(e) is;necessary. The staff recommended specific actions in SECY-97-036,
" Millstone Lessons IIaIthed!5eport, Part 2: Policy issues," dated February 12,1997. In a staff requiremidis herbsrandum dated May 20,1997, the Commission directed the staff, in
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'The termlnnlogy for " updated FSARs* varies throughout the industry. In this guide, the terms updated FSAR, UFSAR,Md,USAR (updated Safety Analysis Report) are equivalent and have the same meanings.
g This regulatory guide is being issued in draf t form to involve the public in the early stages of the development of a regulatory position in this area.
It has not received complete staff review and does not represant an official NRC staff position.
Public comments 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. Wri"en comments may be submitted to the Rules and Disectives Branch, ADM. U.S. Nuclear Regulatory Commission, Washington, DC 20555. Copies of comments received may be examined at the NRC Public
} Document Room,2120 L Street NW., Washington, DC. Comments will be most helpfulif received by April 30,1999.
Requests for eingle copies of draf t or active reguistory guides (which may be reproduced) or for placement on an automatic distribution list for single copies of future draf t guides in specific divisions should be made in writing to the u.S. Nuclear Regulatory Commission. Washington, DC 2035v, Attention: Repro ( vion and Distr bution Services Section, or by f ax to (3o11415-2289, or by email to DISTRIBUTION @NRC. GOV.
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 requirements of 10 CFR Part 50, which were approved by the Office of Management and 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.
I B. DISCUSSION OBJECTIVE The objectives of 10 CFR 50.71(c) 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 i
documant, " Draft industry Update Guidelines for Final Safety Analjsis Reports," to the NRC staff for information. In parallel with industry's efforts, tb 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 Comrmssion in SECY-98-087, dated April 20,1998. In SECY 33-087 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 draf t 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.
In a staff requirements memorandum dated June 30,1998, the Commissior' 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 industry guideline could be endorsed. In an attachment to a meeting summary dated June 15, 1998, the staff provided initial cornments on the draft industry guideline.
NEl submitted a Draft Revision 0 of NEl 98-03, " Guidelines For Updating Final Safety 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 positions of the proposed generic letter and addressed many of the issues raised in the staff's comments provided on June 15,1998, in a lettw dated September 1,1998, the staff pros id comments on Draft Revision 0 of NEl 98-03.
NEl submitted the final version of Draft Revision 0 of NEl 98-03 cn September 30, 1998. The final draft conformed to the staff's comments or provided elturnatives to the staff's proposed resolution of each issue. In a letter dated Octo% 3,1993, the staff provided 2
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[j] endorsement on November 2,1998.
NEl comments on the final draft. NEl then submitted Revision 0 of NEl 98-03 to the ctaff for
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C. REGULATORY POSITION 1.
NEl 98-03 Revision 0 of NEl 98-03, " Guidelines for Updating Final Safety Analysis Reports,"2 dated October 1998, provides methods that are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.71(c).
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.
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 COMMITTFD TO REGUL TORY 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 full'mplementation 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 materialincorporated by reference into the UFSAR, and the following guidance is provided as a clarification to that in NEl 98 03.
Information incorporated by reference into the UFSAR must be provided to the NRC on the licenses'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 l
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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'This docurnent is available for inspection or copying fr / a fee in the NRC Public Document Room,2120 L Street j
NW., Washington, DC; the PDR's mailing address is Ma Stop LL-6, Washington, DC 2055U; phone (202) 634-I 3273; f ax (2021634 3343.
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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.
D.
IMPLEMENTATION The purpose of this section is to provide information to applicants and licensees 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
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acceptable alternative method for complying with specified portions of the NRC's regulations, the methods to be described in the final version of this guin, 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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O, VALUEllMPACT STATEMENT 1
QJ Alllicensees 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 safoty evaluations performed in support of requested license amene nonts, 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 sositions 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 q
fm content of UFSARs was also provided in Generic Letter 80-110, " Periodic Updating of Final i
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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 v
1.70, which deals more with the initial preparation of preliminary and final 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 twc 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 CCR 50.71(e)), and (2) Appendix A contains optional activities that licensees may undertake to improve and simp!ify 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 through 9 is consistent with past staff practices. The guidance in Appendix A represents E relaxation flom prior staff practice in some instances.
Appendix A to NEl 98-03 includes guidance for controlling modifications to the l
UFSAR, including reformatting of information, removing excessive detail, replacing detailed
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i draw.ings wa timplified schematics, referring to other documents and incorporating them by reference, removing obsolete and redundant information, removing commitments, and reporting information removed from the UFSAR to the NRC. Licensees may initiate these voluntary modifications to their UFSARs, unrelated to plant changes or required updates to their UFSARs, to improve the focus, clarity, and maintainability of the UFSAR. In general, j
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this flexibility allowed licensees by P.El 98-03 represents a relaxation frorn previous staff positions. However, the extent to which a particular licensee may benefit from
's implementing NEl 98 03 depends upon the extent to which the licensee chooses to 5
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implement the pt as 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 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. 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 comment. 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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