ML20206G812

Forwards Comments on Draft Reg Guide DG-1083, Content of UFSAR IAW 10CFR50.71(e), Dtd Mar 1999.Util Generally Supports DG-1083

ML20206G812
Person / Time
Site:	Nine Mile Point
Issue date:	04/30/1999
From:	Terry C NIAGARA MOHAWK POWER CORP.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
TASK-*****, TASK-RE NMP1L-1431, NUDOCS 9905100150
Download: ML20206G812 (7)

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Carl D. Terry Phone: 315.389.7263 Vice President Fax: 315.349.4753 1 Nucleu Safety and Assessment and Support April 30, 1999 NMPIL 1431 Chief, Rules and Directives Branch I Office of Administration U.S. Nuclear Regulatory Commission I Washington, DC 20555 l RE: Nine Mile Point Unit 1 Nine Mile Point Unit 2 l' Docket No. 50-220 Docket No. 50-410 DPR-63 NPF-69

Subject:

Comments on Draft Regulatory Guide DG-1083, " Content of the Updated Final l' Safety Analysis Report in Accordance with 10 CFR 50. 71(c)"

Gentlemen:

Niagara Mohawk Power Corporation (NMPC) appreciates the opportunity to comment on Draft  !

Regulatory Guide DG-1083, " Content of the Updated Final Safety Analysis Report in Accordance  !

I with 10 CFR 50.71(e)," dated March 1999.

I NMPC generally supports the Commission's Draft Regulatory Guide DG-1083, including the 3 '

staff s proposed larguage for a founh bullet in Section A2 and the proposed clarification to Section A4.3 regarding information incorporated by reference. There are, nevertheless, several l aspects of NEI 98-03 that warrant additional comments. We encourage the Staff to consider the  ;

comments provided in the enclosed attachment.

Sincq, J '

9905100150 990430 DR ADOCK 05 o Carl D. Terry p  !

Vice President i Nuclear Safety Assessment and Support l CDTl]IIJkap *q  ;

Attachment I 's /

1 xc: Mr. H. J. Miller, NRC Regional Administrator ,[  !

Mr. G. K. Hunegs, Senior Resident Inspector ,/dd()) f Ii Mr. S. S. Bajwa, Director, Project Directorate I-1, NRR Mr. D. S. Ilood, Senior Project Manager, NRR Mr. R. J. Bell, NEI ,

Records Management Document Control Desk j Nine Mile Point Nudear Stauon P0. Box 63, Lycoming Pbw York 13093-0063 + www nimo.com

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NMPC COMMENTS REGARDING NEI 98-03 1

1 NEI 98-03 Section Comment Basis  !

I Section 2, Page 1 Last sentence should read: The UFSAR is periodically Second paragraph "The industry has developed revised to reflect this guidance in recognition of facility / procedure changes the importance of the USFAR and to capture the current to reflect the current licensing licensing basis. The UFSAR l basis and to comply with is rarely, if at all, consistent 1 10 CFR 50.71(e) update with the plant configuration I requirements." and operation. The UFSAR can be as much as 6 months out of date as of the date of filing a revision.

l Section 3.6, Page 2 The reference to offsite 10 CFR 50.34(a)(1) does not exposures" comparable to the provide offsite exposure guidelines in 10 CFR guidelines.

50,34(a)(1)" does not appear to be correct.

Section 3.8, Page 3 Suggest rewording as folloves: To simplify definition.

"The Updated FSAR (UFSAR)is the original FSAR as updated per th::

requirements of 10 CFR 50.71(e)"

Section 4, Page 3 The last sentence reads:"The There is no basis or purpose UFSAR also serves to provide for the statement. As the general public a indicated by the rule (10 CFR description of the plant and its 50.71(e)(1), the licensee is operation." This sentence only required to send the should be deleted. updated FSAR to the NRC.

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NMPC COMMENTS REGARDING NEI 98-03  ;

i NEI 98-03 Section Comment Basis Section 5, Page 4 Third paragraph should be Additional clarification I

expanded to acknowledge that regarding the scope of the the QA Program Description UFSAR.

and Site Emergency Plan were also initially submitted and reviewed as part of the original FSAR under 10 CFR 50.34(b)(6)(ii) and (v).

However, these documents are now controlled separately per 10 CFR 50.54(a) and 10 CFR 50.54(q).

Section 6.1, Page 6 First paragraph, first sentence For consistency with replace the word regulation terminology (e.g.,

" configuration" with the word 10 CFR 50.34(b)(2) states:

" design". Suggest rewording "The description shall be first sentence to read:"10 sufficient to permit CFR 50.71(e) requires understanding of the system licensees to periodically designs and their relationship update their UFSARs to to safety evaluations").

assure they remain up-to-date such that they accurately reflect the plant design and operation."

Section 6.1, Page7 Although Subsection 6.1.2 To provide consistency in describes " changes in the addressing the particular facility or procedures," and aspects of 10 CFR 50.71(e).

Subsection 6.1.3 describes

" analyses of new safety issues," there is no Subsection to describe the effects of"all safety evaluations performed by the licensee." Recommend Subsection 6.1.1 be merged with 6.1.3, Subsection 6.1.2 ,

be renumbered 6.1.1, and 6.1.2 be used to describe the

" effects of all safety evaluations."

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NMPC COMMENTS REGARDING NEI 98-03 l

l NEI 98-03 Section Comment Basis l Section 8, Page 11 First paragraph, first sentence For consistency with 10 CFR should read:"The UF3AR is 50.71(e). Based on 10 CFR revised periodically to assure 50.71(e), the UFS AR is not that the information included intended to be consistent with in the UFSAR contains the plant configuration or latest material developed." operation. It may be, and typically is at most,6 months out of date at time of filing.

Section 8, Page 11 Second paragraph, second 18-24 months should be sentence should read: replaced with 6-30 months to "Because UFSAR information be consistent with 10 CFR may lag the current plant 50.71(e).

status by 6-30 months, the UFSAR is an inefficient vehicle for documenting temporary conditions."

Section 8, Pagel1 Third paragraph, last sentence As a point of clarification, a should read:"For temporary report is submitted to the changes subject to 10 CFR NRC in accordance with 10 50.59, evaluations are CFR 50.59(b), not the performed and a report evaluations.

submitted to the NRC in accordance with 10 CFR 50.59(b)."

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NMPC COMMENTS REGARDING NEI 98-03 NEI 98-03 Section Comment Basis Section 8, Page 11 Last paragraph, first sentence Guidance regarding" clearly reads: "Temporatf identified"is too subjective.

modifications reflected in the The words "as appropriate" UFSAR should be clearly provide adequate guidance.

identified as such to Also, the words " design" and distinguish temporary " normal operation" are conditions from the permanent consistent with the language plant configuration." of10CFR 50.34(b). The word " configuration" is not.

This should be revised to read:

" Temporary modifications reflected in the UFSAR should be identified, as appropriate, to distinguish temporary conditions from permanent plant design and normal operation."

Section 8, beginning on Page The last sentence on page 11 Funher clarification is 11 and continuing on page 12 required to understand the reads:" Consistent with purpose of the statement.

licensee configuration control procedures, there may be temporary modifications reflected in the UFSAR that are not reflected in other permanent plant documentation." Based on the nature of the UFSAR, as it typically describes other l documents (e.g., drawings, specification, calculations and changes thereto)NMPC does not understand how this can be possible.

Section 8, Page 12 Example 2,last sentence To be consistent with the should read, in part: "When previous sentence (i.e., i the modification..." rather than evaluate the temporary "Because the modification..." modification per Section 6 of '

the guideline).

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NMPC COMMENTS REGARDING NEI 98-03 NEI 98-03 Section Comment Basis Section 8, Page 12 Example 3 should read,in The be consistent with the part: "When the previous sentence (i.e.,

modification.. "rather than evaluate the temporary "Because the modification..." modification per Section 6 of the guideline).

Section 9, Page 13 Second paragraph reads:"If The guidance suggests that evaluation of the discrepancy 10 CFR 50.59 does not apply determines that the UFSARis when an evaluation incorrect, a correction should determines that the UFSAR is ]

be initiated in accordance with incorrect. If this is not the thelicensee procedures for intent, clarification is inclusion in the next UFSAR required.

update." This guidance appears to imply that a 10 CFR 50.59 evaluation of the actual facility configuration would not be required.

Appendix A, Page 1 The last sentence of Section This guidance appears to be Al reads:"While not inconsistent with guidance discussed in this document, provided in Section 3.7, 1:censees also may add Section 4, Section 5, Section information that goes beyond 6, and especially Section regulatory requirements and A4.1. Section A4.1 reads in guidance to facilitate use of part:" Removal of excessively the UFSAR by plant staff or detailed text and drawings for 9ther purposes." To can improve the focus of remain consistent with the UFSARs on significant purpose of the UFSAR and to descriptive, design bases, be consistent with the intent of operational and analytical NEI 98-03, NMPC proposes information that is relevant that the last sentence of Al be and useful to support current deleted, and future operational and regulatory activities."

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. l NMPC COMMENTS REGARDING NEI 98-03 NEI 98-03 Section Comment Basis )

Appendix A, Section A4.3 This section suggests NMPC considers the removing information (from Emergency Plan, Offsite Dose the UFSAR) that is duplicated Calculation Manual, Security  ;

in separate, controlling Plan, Environmental program documents such as Protection Plan, and Quality the Emergency Plan, Offsite Assurance Program  !

Dose Calculation Manual, Fire description to be separate (

Protection Plan and Fire from the UFSAR. When }

Hazards Analysis Report, independent of each other, TechnicalRequirements the appropriate provisions of Manual, Security Plan, 10 CFR 50.59 are applied to  ;

Environmental Protection proposed facility and  !

Plan, and Quality Assurance procedure changes as  ;

Plan, then incorporating the described in the UFSAR, information back into the while Plan and Program j UFSAR by reference. This changes are appropriately l action does not appear to considered under the  ;

simplify the UFSAR. NMPC provisions of10 CFR 50.54, recommends this subject be the facility operating license, given further consideration by or plant technical i NEI or the NRC. specifications. The j incorporation of these  :

documents into the UFSAR l by reference, in an effort to f simplify the UFSAR, would j require the application of j 10 CFR 50.59 provisions to changes to these documents.

This is inconsistent with the very nature and intent of 10 CFR 50.59,10 CFR 50.54 (a),10 CFR 50.54(p), and 10 CFR 50.54(q).

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