ML20205D254

Comments on Failure of Rev 1 to Updated SAR for Facility to Comply w/10CFR50.71(e)(5).Corrective Action Re Potential Jeopardy of Intent & Usefulness of Rept Requested

ML20205D254
Person / Time
Site:	River Bend
Issue date:	10/17/1988
From:	Plettinger H AFFILIATION NOT ASSIGNED
To:	Paulson W Office of Nuclear Reactor Regulation
References
NUDOCS 8810270086
Download: ML20205D254 (2)

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H. ANNE PLETTLNGER M 56 Villa Poso Drive 8ATON ROUGE LOUISlANA 70000 5 % 343 9333 October 17, 1988 Mr. Welter Paulson, Project Manager.

Project Directorato - IV Division of Reactor Projects U.S.Nucicar Regulatory Commission Washington, D.C. 20555 Gulf States Utilities Co Rivo- Bend Station Unit 1 Docket No. 50-458

Dear Mr. Paulson:

Recently, I referred to the River Bond (RB) Updated Safety Analysis Report (USAR) and was surprised to find that Revision 1 (August 1988) has been submitted to and accepted by the NRC although it appears to not fully comply with 10CFR50.71.

Specifically, 10CFR50.71(e)(2)(i) states, in part:

The submittal shall include (i) a certification by a duly authorized officer of the licensee...

(Emphasis added).

10CFR50.71(e)(5) states:

Each replacement pago ,shall include both a change indicator for the area changed,0.g., a bold line vertically drawn in the margin adjacent to the portion actually changed and a page change identification (date of change or chanco number or both). (Emphasis added).

Contrary to the above, the submittal's cortification was by the Manager - River Bend Oversight rather than a "duly authorized officer". The initial Update (August 1987)of the Final Safety Analysis Report (thereafter referred to as the USAR) was submitted and cortified by Mr. J. C. Doddens, Senior Vice President, River Bond Group.

Revision 1 failed to meet the requirements of 10CFR50.71(c)(5).

Small "special symbols" described in the transmittal lotter (RBG-28565) dated August 25, 1988 are substituted for the "bold line vertically drawn in the margin adjacent to the portion actually changed". The "special symbols" are not vertically placed in the margin but are horizontally placed on the left, above and below the area changed. They are small and not as conspicuous as the vertical change-bar. The date of the chango at the bottom of the page is not accompanied by a revision number. In other words, the practice that GSU consistently used in amending the River Bend 8310070086 681017 0 PDR ADOCK 05000458 hk PDC

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PSAR and FSAR has been changed to one not in compliance with 10CFR50.71(c)(5).

In addition, the Tables of Content are without change indicators for the Sections revised. For examplo, reference is made on page 13A-24 (August 1987) to Section 13.1.1.2.8. Page 13-11 of The Table of Contents is devoid of any change indicators. There is no Section 13.1.1.2.8 listed. It appears to have been replaced by Section 13.1.1.2.6. Undoubtedly, other discropancies between unrovised and revised Sections can be found. I suspect this could make cross-referencing more difficult and could have the potential for confusion.

In my opinion, if this lack of conformity with 10CFR50.71(c)(5) romains uncorrected, the intent and the future usefulness of the RBS USAR could be jeopardized. For those reasons, I bring this mattor to your attention for correctivo action.

Sincerely,

,* ? /!n. n e. ik <!QL li . Anne Plottinger I

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