ML20206N445

Comment Supporting Draft RG DG-1083, Content of UFSAR 10CFR50.71(e)

ML20206N445
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
FRN-64FR13833, RTR-REGGD-01.070, RTR-REGGD-1.070, TASK-*****, TASK-RE 64FR13833-00007, 64FR13833-7, NMP1L-1431, NUDOCS 9905170230
Download: ML20206N445 (7)

Text

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} RECENED Carl D. Tony Vice President g g / % $ 34

• Phone: 315.349.7263 Fax: 315.349.4753 Nucl. r Safety and Assessment and Support is. BRhNCH April ,1 4g0 NMPIL 1431 Chief, Rules and Directives Branch Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555 i

RE: Nine Mile Point Unit 1 Nine Mile Point Unit 2 Docket No. 50-220 Docket No. 50-410 DPR-63 NPF-69

Subject:

Comments on Draft Regulatory Guide DG-1983, " Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50. 71(e)"

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

NMPC generally supports the Commission's Draft Regulatory Guide DG-1083, including the stafl's proposed language for a fourth bullet in Section A2 and the proposed clarification to Section A4.3 regarding information incorporated by reference. There are, nevertheless, several aspects of NEI 98-03 that warrant additional comments. We encourage the Staff to consider the comments provided in the enclosed attachment.

Since ,

D, 9905170230 990430 Carl D. Terry i .

oso7b PDR ,

Vice President l  ;

Nuclear Safety Assessment and Support /

CDT/JJIlkap 05 '

Attachment xc: Mr. H. J. Miller, NRC Regional Administrator Mr. G. K. Hunegs, Senior Resident Inspector Mr. S. S. Bajwa, Director, Project Directorate I-1, NRR Mr. D. S. Hood, Senior Project Manager, NRR Mr. R. J. Bell, NEI Records Management Document Control Desk Nine Mde Point Nucieer station P0. Box 63. Lycoming. New York 13093-0063

• www nimo.com

NMPC COMMENTS REGARDING NEI 98-03 NEI 98-03 Section Comment Basis 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 j to reflect the current licensing licensing basis. The UFSAR '

basis and to comply with is rarely, if at all, consistent 10 CFR 50.71(e) update with the plant configuration  !

requirements." and operation. The UFSAR )

can be as much as 6 months out of date as of the date of filing a revision.

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

50.34(a)(1)" does not appear l to be correct. I Section 3.8, Page 3 Suggest rewording as follows: To simplify definition.

"The Updated FSAR l

, (UFSAR)is the original FSAR as updated per the 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 '

NEI 98-03 Section Comment Basis Section 5, Page 4 Third paragraph should be Additional clarification 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). I However, these documents  !

are now controlled separately I per 10 CFR 50.54(a) and 10 )

CFR 50.54(q).

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1 Section 6.1, Page 6 First paragraph, first sentence For consistency with j 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 l first sentence to read:"10 sufficient to permit I CFR 50.71(e) requires understanding of the system licensees to periodically designs and their relationship update their UFSARs to to safety evaluations"). l assure they remain up-to-date i 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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l-l' NMPC COMMENTS REGARDING NEI 98-03 I

I NEI 98-03 Section Comment Basis Section 5, Page 4 Third paragraph should be Additional clarification 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 3 l 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 l 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 l update their UFSARs to to safety evaluations").

l assure they remain up-to-date such that they accurately

reflect the plant design and l

operation."

Section 6.1, Page7 Although Subsection 6.1.2 To provide consistency in L 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 l issues," there is no Subsection l 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." l 2 of 6

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NEI 98-03 Section Comment Basis Section 8, Page 1I First paragraph, first sentence For consistency with 10 CFR should read:"The UFSAR is 50.71(e). Based on 10 CFR revised periodically to assure 50.71(e), the UFSAR 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.

I 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 l 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, Pagell 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:" Temporary 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 j plant design and normal operation."

I Section 8, beginning on Page The last sentence on page 11 Further clarification is  !

11 and continuing on page 12 required to understand the I reads:" Consistent with purpose of the statement. I licensee configuration control procedures, there may be temporary modifications reflected in the UFSAR that are not reflected in other j permanent plant i documentation." Based on the nature of the UFSAR, as it typically describes other 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 j should read, in part: "When previous sentence (i.e., i the modification.. " rather than evaluate the temporary l "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 Seco:, oaragraph reads:"If The guidance suggests that eva'ne .on of the discrepancy 10 CFR 50.59 does not apply d ttrmines that the UFSAR is when an evaluation incorrect, a correction should determines that the UFSAR is be initiated in accordance with incorrect. If this is not the the licensee 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, licensees 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 other 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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F 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 ofeach other, Technical Requirements 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 UFSAR by reference. This changes are appropriately 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 NEI or the NRC. specifications. The incorporation of these documents into the UFSAR by reference,in an effort to simplify the UFSAR, would require the application of 10 CFR 50.59 provisions to  ;

changes to these documents. l This is inconsistent with the i very nature and intent of I 10 CFR 50.59,10 CFR 50.54  !

(a),10 CFR 50.54(p), and 10 l CFR 50.54(q).  ;

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