ML20206M511
| ML20206M511 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/30/1999 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-64FR13833, RTR-REGGD-01.070, RTR-REGGD-1.070, TASK-*****, TASK-RE 64FR13833-00011, 64FR13833-11, TXX-99112, NUDOCS 9905140274 | |
| Download: ML20206M511 (2) | |
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MI Log # TXX-99112 #NTI M Mff m
gj PECElVED p 5-File # 10010 1999 MAY -5 AM 9: 5E E
//
p RULES & D!R. BRANNELECTR/C US NRC April 30,1999
- c. u w,,y Senior Hee President
& PrincipalNuclear Oficer :
- Rules and Directives Branch Office of Administration U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC ST/$ TION (CPSES)
DOCKET NOS. 50-445 AND 50-446 Comments on Draft Regulatory Guide 1083, " Content of the Update Final Safety Analysis Report in Accordance with 10 CFR 50.71(e)" (64 Fed. Reg.13833 - March 22,1999)
Gentlemen:
The NRC requested comments on DG-1083 as part of the process leading to agency endorsement of NEl 98-03, Guidelines for Updating FSARs. TU Electric generally endorses DG-1083, including the NEl comments provided to the NRC dated April 30,1999. However, we have reservations concerning the NRC position on " incorporation by reference." The CPSES FSAR is formatted in accordance with Regulatory Guide (RG) 1.70, Standard Format.
Consistent with RG 1.70, FSAR Section 1.6, which is entitled, Material /ncorporated by Reference, lists over 130 Topical Reports which were provided to the NRC in support of the CPSES Units 1 and 2 Operating Licenses. It is not clear to what extent this current list of topical reports would be expected to conform to the DG-1083 guidance for updates in accordance with 10CFR50.71(e) and 10CFR50.59. A literal read of that guidance would.suggest that, per 10CFR50.71(e), replacement pages would be required to be provided to the NRC for all
- revisions to documents " incorporated by reference."
TU electric recommends the following approach be adopted for changes to documents which are
Changes to information " incorporated by reference" would be subject to the requirements of 10CFR50.59 and 10CFR50.71(e) only when such changes are adopted by the licensee. At the time of adoption, a review under 10CFR50.59 would be performed and the FSAR subsequently
. updated per 10CFR50.71(e) to reflect the later version of the referenced document. The f
information provided to the NRC with regard to such changes would be the 10CFR50.71(e) g required replacement FSAR page listing the later version of the referenced document (e.g., new revision number and/or date) and the 10CFR50.59 summary of the changes to the referenced
. document. In general, replacement pages for the referenced document would nQ1 be provided.
9905140274 990430 PDR REGOD 01.070 C PDR j /j i ' ' ' ';.,
COMANCHE PEAK SIEAM ELECTRIC STATION P.O. Box 1002 Glen Rose. Texas 76043 1002
y TXX-99112 Page 2 of 2 j
1 This communication contains no new commitments or revised commitments. Should you have l
any questions, please contact Mr. B.(Bob) S. Dacko at (254) 897-0122.
Sincerely, C. L. Terry By:
M RogerD. Walker Regulatory Affairs Manager BSD/bsd c-D. H. Jaffe, NRR Anthony P. Pietrangelo, NEl