ML20211N287
| ML20211N287 | |
| Person / Time | |
|---|---|
| Issue date: | 08/04/1999 |
| From: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| RTR-REGGD-01.181 SECY-99-203, SECY-99-203-01, SECY-99-203-R, NUDOCS 9909100139 | |
| Download: ML20211N287 (41) | |
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..................... 3a POLICY ISSUE Auaust 4.1999 (Notation Vote) sscy_,,_203 EOB:
The Commissioners FROM:
William D. Travers Executive Director for Operations
SUBJECT:
REGULATORY GUIDE FOR UPDATED FINAL SAFETY ANALYSIS REPORTS IN ACCORDANCE WITH 10 CFR 50.71(e)
PURPOSE:
To obtain the Commission's approval to publish Regulatory Guide (RG) 1.181 (Attachment 1).
1
SUMMARY
l The staff recommends that the Commission approve publication of RG 1.181," Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e)." RG 1.181 endorses the industry guideline document developed by the Nuclear Energy Institute (NEI),
NEl 98-03, Revision 1, " Guidelines for Updating Final Safety Analysis Reports," dated June 1999 (Attachment 2), without exception. The staff believes that NEl 98-03 presents an acceptable method for compliance with 10 CFR 50.71(e) and also gives suitable guidance for modifying the content and format of the updated final safety analysis report (UFSAR'), giving licensees considerable flexibility and the opportunity to reduce the burden associated with maintaining the UFSAR. NEl 98-03, Revision 1, has incorporated all appropriate staff and public comments received on NEl 98-03, Revision 0, and draft regulatory guide DG-1083,
" Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e)."
DACKGROUND:
Section 50.34 (10 CFR 50.34), " Contents of Applications; Technical Information," contains requirements for the material to be submitted in applications for construction permits and operating licenses for nuclear power reactors. An application for a construction permit must f
contain a preliminary safety analysis report (PSAR) pursuant to 650.34(a). An application for an g
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Joe Birmingham, NRR 301 415-2829 2'
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u y C A M - [. C/,+ r' b The terminology for updated final safety analysis reports varies throughout the industry.
The terms " updated FSAR, UFSAR, and USAR (updated safety analysis report)" are equivalent.
9909100139 990804 PDR SECY 99-203 R PDR
a-I
.. operating license must contain an FSAR in accordance with $50.34(b). For holders of operating licenses, $50.71(e) requires the FSAR to be periodically updated (i.e., the updated FSAR or UFSAR).2
--Guidance for the organization and content of PSARs and FSARs has existed since June 30, 1966, when the Atomic Energy Commission issued " Guide to the Organization and Contents of Safety Analysis Reports." The most recent guidance document is RG 1.70, Revision 3,
" Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants, LWR Edition," dated November 1978. Limited guidance for the format and content of UFSARs was previously issued in Generic Letter 80-110, " Periodic Updating of Final Safety Analysis Reports (FSARs)," dated December 15,1980.
As a result of lessons loamed from the Millstone experience and from other initiatives related to UFSARs, the NRC determined that additional guidance was needed about compliance with
$50.71(e). The staff recommended specific actions in SECY-97-036, " Millstone Lessons Leamed Repod, Part 2: Policy issues," dated February 12,1997, in a staff requirements memorandum (SRM) dated May 20,1997, the Commission directed the staff, in part, to issue guidance for complying with $50.71(e) to ensure that UFSARs are updated to reflect changes to the design bases and to reflect the effects of other analyses performed since original licensing that should have been included under $50.71(e). The Commission suggested that this guidance include a risk-informed approach for prioritization and content of the UFSAR, allow removal of certain information from the UFSAR, and consider whether the period of enforcement discretion regarding UFSARs should be extended. In the SRM dated March 24, 1998, concoming SECY-97-205, " Integration and Evaluation of Results From Recent Lessons-Leamed Reviews," dated September 10,1997, the Commission reemphasized the need for guidance for UFSARs and further requested that guidance be prepared for plants undergoing decommissioning.
The staff responded, in part, to the SRMs of May 20,1997, and March 24,1998, with SECY-98-087. In that paper, the staff recommended that the Commission approve issuance of the staff's proposed generic letter as interim guidance on the content of UFSARs. The staff further proposed to continue to resolve staff issues with the preliminary version of NEl 98-03, with the goal of endorsing NEl 98-03 as the final guidance in a regulatory guide. The staff's proposed generic letter responded to the Commission's request for guidance on the content of the UFSAR, aliowed removal of certain information, made the guidance applicable to plants undergoing decommissioning, and proposed a method for extending the enforcement discretion period for UFSARs that was risk informed (risk-informed prioritization). The staff noted that a risk-informed UFSAR content could not be achieved without rulemaking.
The staff recommended that the proposed generic letter be issued at that time because the staff could not endorse the preliminary version of NEl 98-03 without rulemaking. In particular, the staff had concems with the industry positions regarding removal of certain historical information required to be in a UFSAR, removal of ill-defined " obsolete" and "less meaningful" 2Paragraph 50.71(f) extends the requirements of $50.71(e) to decommissioning facilities, that is, those nuclear power reactor licensees that have submitted the certification of i
permanent cessation of oper,ations required under $50.82(a)(1)(i).
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. information that may not have been allowed by the regulations, and the substitution of simplified schematics for piping and instrumentation diagrams without ensuring that the UFSAR continued to contain all required information.
in an SRM dated June 30,1998, the Commission disapproved issuance of the proposed generic letter except under certain circumstances and directed the staff to continue to resolve differences between the proposed generic letter and NEl 98-03. The Commission also directed the staff to establish an enfotrement discretion period for UFSARs for a 6-to 18-month period after the final guidance was issued, depending on risk significance.8
- After several public meetings with the staff to resolve differences between the proposed generic letter and NEl 98-03, NEl submitted Revision 0 of NEl 98-03 to the staff for endorsement in October 1998. Upon finding Revision 0 acceptable, the staff drafted DG-1083, which proposed endorsing NEl 98-03, Revision 0, and forwarded both documents to the Commission in SECY-99-001, " Proposed Guidance for Updated Final Safety Analysis Reports
. in Accordance With 10 CFR 50.71(e)," dated January 5,1999. In that paper, the staff recommended that the Commission approve issuance of DG-1083 for public comment. In an
. SRM dated February 16,1999, the Commission approved the staff's recommendation.
DISCUSSION:
Public Comments A total of 14 public comment letters were received on DG-1083. Thirteen were from licensees, and the other was from NEl. In general, most of the licensees supported NEl's comments and offered additional comments. When additional comments were provided, for the most part they concemed NEl 98-03, Revision 0, and not DG-1083.
The comments on NEl 98-03, Revision 0, were discusser; with NEl at a public meeting on May 11,1999, and were provided in a meeting summary dated May 19,1999. The majority of l
the comments were of an editorial nature or corrected minor errors in NEl 98-03, Revision O.
When appropriate, NEl incorporated the minor changes into Revision 1. In addition, several substantive comments were received and were incorporated into Revision 1, as discussed further below.
aThe staff addressed this item with Enforcement Guidance Memorandum 98-007,
" Extension of Exercise of Discretion for FSAR Discrepancies identified While the Licensee Has a Defined Program for identifying Such Discrepancies," dated September 15,1998.
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. Except for Regulatory Position C.5, " incorporation by Reference," no substantive comments were provided on DG-1083, although some minor changes were made as suggested by the commenters.
Differences Between Revision 1 and Revision 0 of NEl 98-03 Overall, NEl made few changes to NEl 98-03. The substantive changes concemed (1) incorporation by reference; (2) retention of information associated with systems, structures, and components (SSCs) of safety significance; (3) removal of drawings from the UFSAR; and (4) removal of commitments.
1.
Incorporation by
Reference:
This topic received the most comments. Most comments concemed the proposal by the staff, as described in SECY-99-001, to clarify NEl 98-03,-
Revision 0, by incorporating Regulatory Position C.5 in DG-1083. The staff position in DG-1083 was that since materialincorporated by reference was part of the UFSAR, such material had to be on the docket and was subject to the requirements of $50.59 and $50.71(e), including the associated reporting requirements.
The concem of some commenters was that this approach departed from past practice and would impose a substantial burden with respect to keeping vendor and topical information up to date on the docket. Therefore, the consensus was that requiring maintenance of this information on the docket file would be inappropriate. The staff concurs with this comment and did not intend that all vendor and topical information be redundantly provided on each applicable licensee's docket file. Therefore, the staff suggested at the public meeting with NEl on May 11,1999, that Revision 1 instead note
- that information incorporated by reference had to be on file with the NRC (but did not '
need to be maintained on each docket file). In addition, the staff suggested that NEl provide a specific example, using the Technical Requirements Manual (TRM), to j
demonstrate the impact of different approaches to referencing the TRM.
l The staff finds that NEl has incorporated this comment (including the TRM example) into Revision 1 in an acceptable manner. Therefore, Regulatory Position C.5 is no longer needed in RG 1.181.
2.
Retention of Information Associated With SSCs of Safety Sionificance: As noted in SECY-99-001 and in the Federal Register notice for DG-1083, the staff proposed that NEl 98-03, Revision 0, be clarified to note that even when no explicit requirement existed, NEl 98-03 was not intended to be used to remove information associated with SSCs of safety significance from the UFSAR. Although. retention of this information j
would be voluntary, the staff believed that this additional guidance would clarify the intent of NEl 98-03 with respect to removal of less meaningful and obsolete information.
In its comment letter, NEl stated its intent to incorporate language into Revision 1 consistent with that proposed by the staff. Three licensees were opposed to the inclusion of such guidance absent an exolicit requirement. NEl did incorporate this clarification into Revision 1, and the staff finds the addition acceptable.
5-3.
Removal of Drawinos: Revision 1 includes additional guidance for the conditions under which it is acceptable to remove a drawing from the UFSAR. The criteria are consistent with the existing guidance in Revision 0 for the removal of descriptive information. The staff finds the additional guidance acceptable.
4.
Removal of Commitments: At the public meeting with NEl on May 11,1999, the staff noted that Revision 0 could be interpreted to allow the removal of allcommitments from the UFSAR. The staff suggested that the guidance be clarified to limit the commitments that can be removed to those that are obsolete or less meaningful. NEl modified NEl 98-03 to address the staff's concem. The staff finds the clarification in Revision 1 acceptable.
Publication of RG 1.181 The staff has found the guidance in NEl 98-03, Revision 1, to be acceptable and is proposing l
to endorse NEl 98-03 in RG 1.181 as one acceptable method for complying with $50.71(e).
The g' idance in NEl 98-03, Revision 1, is generally consistent with Revision 0 and DG-1083 u
and, where Revision 1 differs, the staff finds the altamative proposed by NEl to be acceptable.
l As previously noted, NEl incorporated the one clarification in DG-1083 (Regulatory Position C.5, " incorporation by Reference") into Revision 1 such that RG 1.181 does not need that regulatory position. Therefore, RG 1.181 endorses NEl 98-03, Revision 1, without exception or clarification.
I CONCLUSIONS:
The staff finds that the guidance in NEl 98-03, Revision 1, provides an acceptable method for l
compliance with $50.71(e). NEl 98-03 also contains provisions that allow licensees to improve and simplify the content and format of their UFSAR in a manner that is acceptable to the staff.
The staff has developed a regulatory guide, RG 1.181, that endorses NEl 98-03, Revision 1, l
without exception.
IMPLEMENTATION:
As part of its regulatory oversight activities, the staff will monitor plant specific FSAR updates.
The staff will pay particular attention to plants that implement Appendix A to NEl 98-03 to determine whether the guidance permits the removal of information that the staff believes is important to risk determinations or the conduct of regulatory business. The staff is also currently working on guidance to clarify the types of information that are considered design bases. Because this guidance will directly affect the content of the FSARs, and because of the difficulty in objectively defining what constitutes sufficient level of detail, the staff will also monitor the use of the design bases guidance for both the updating of the FSAR and the level of detail of the design basis. Based upon our activities, the staff will determine whether the guidance for design bases or FSAR updates or both needs to be modified.
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l.J RESOURCES:
The resources necessary to complete the activities related to issuing the final regulatory guide are currently budgeted for Fiscal Year 1999. No additional staff resources are necessary to train the appropriate staff beyond those resources previously identified in SECY-97-205 and SECY-98-087. Approximately 1.5 FTE have been projected for both FY2000 and FY2001 for staff activities to monitor licensee efforts to update the FSARs (about 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per FSAR update).
COORDINATION:
l The Office of the General Counsel has no legal objection to this paper or to publication of the proposed regulatory guide. The Office of the Chief Financial Officer has reviewed this Commission paper for resource implications and has no objections. The Committee to Review i
Generic Requirements and the Advisory Committee on Reactor Safeguards have endorsed the l
regulatory guide.
I RECOMMENDATION:
The staff recommends that the Commission approve publication of the regulatory guide, RG 1.181, as one acceptable method for compliance with $50.71(e).
i h
William D. Travers
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Executive Director for Operations l
Attachments: 1. Regulatory Guide RG 1.181 1
- 2. Revision 1 of NEl 98-03 l
Commissioners' completed vote sheets / comments should be provided directly to j
the Off. ice of the Secretary by COB Thursday, August 19, 1999.
Commission Staff Office comments, if any, should be submitted to the Commissioners l
NLT August 12, 1999, with an information copy to the Office of the Secretary.
If the paper is of iuch a nature that it requires additional review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
Commissioners ACRS
August 1999 REGULATORY GUIDE 1.181 (Draft was issued as DG-1083)
CONTENT OF THE UPDATED FINAL SAFETY ANALYSIS REPORT IN ACCORDANCE WITH 10 CFR 50.71(e)
A. INTRODUCTION in 10 CFR Part 50," Domestic Licensing of Production and Utilization Facilities,"
Section 50.34, " Contents of Applications; Technical Information," contains requirements for the contents of applications for construction permits and operating licenses for nuclear power reactors. An application for a construction permit must include a preliminary safety analysis report (PSAR) pursuant to 10 CFR 50.34(a). An application for an operating license must include a final safety analysis report (FSAR) in accordance with 10 CFR 50.34(b). For holders of operating licenses,10 CFR 50.71(e) requires updated FSARs' to be developed and periodically updated.
Guidance for the organization and contents of PSARs and FSARs has existed since June 30,1966, when the " Guide to the Organization and Contents of Safety Analysis Reports" was issued. The most recent guidance document is Revision 3 of Regulatory Guide 1.70,
" Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants (LWR Edition),"(November 1978). Limited guidance for the format and content of UFSARs was also provided in Generic Letter 80-110 " Periodic Updating of Final Safety Analysis Reports (FSARs)" (December 15,1980).
As a result of lessons learned from the Millstone experience and other initiatives related to UFSARs, the NRC has determined that additional guidance regarding compliance with 10 CFR 50.71(e) is necessary. The staff recommended specific actions in SECY {
036," Millstone Lessons Learned Report, Part 2: Policy issues," dated February 12,1997. In a staff requirements memorandum dated May 20,1997, the Commission directed the staff, in 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 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.
'The terminology for " updated FSARs* varies throughout the industry, in this guide, the terms updated FSAR, UFSAR, and USAR (updated Safety Analysis Report) are equivalent and have the same meanings.
1 1
ATTACHMENT 1
1 B. DISCUSSION OBJECTIVE 4
The objectives of 10 CFR 50.71(e) are to ensure that licensees maintain the information in the UFSAR to reflect the current status of the facility and address new issues
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as they arise, so that the UFSAR can be used as a reference document in safety analyses.
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. DEVELOPMENT OF INDUSTRY GUIDELINE, NEl 98-03 On November 14,1997, the Nuclear Energy Institute (NEI) provided a draft guidance document, NEl 98-03, " Draft Industry Update Guidelines for Final Safety Analysis Reports," to the NRC staff for information. In parallel with industry's efforts, the 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 Commission in SECY-98-087,8 dated April 20,1998. In SECY 98-087, 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 draft 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 Commission 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.
1 Subsequently, the NRC staff held public meetings with NEl to resolve the differences between the documents, which resulted in NEl submitting Revision 0 of NEl 98-03 to the NRC staff for endorsement in November 1998. The NRC staff proposed endorsing Revision 0 of NEl 98-03 in the draft version, DG-1083, of this Regulatory Guide 1.181. DG-1083 was issued for public comment in March 1999.
After the public comment per.iod, the staff held a public meeting with NEl to discuss the public comments received, the NRC staff comments, and the clarification of Revision 0 of NEl 98-03 in Regulatory Position 5 of DG-1083. NEl then submitted Revision 1 of NEl 98-03 in June 1999 for NRC endorsement in this regulatory guide. Revision 1 of NEl 98-03 incorporates the public comments, the NRC staff's comments, and Regulatory Position C.5 from DG-1083.
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- Copies' are available for inspection or copytrq tor a fee from the NRC Public Document Room at 2120 L street NW., Washington, DC; the PDR's mailing address is Mail stop LL 6, Washington. DC 20555; telephone (202)634-3273; fax (202)634 3343.
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C. REGULATORY POSITION 1.
NE! 96-03 Revision 1 of NEl 98-03," Guidelines for Updating Final Safety Analysis Reports,"2 dated June 1999, provides methods that are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.71(e).
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 all licensees. A licensee should ensure that an example is applicable to its particular circumstances before implementing the guidance as described in an example.
4.
LICENSEES COMMITTED TO REGULATORY 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 fullimplementation of NEl 98-03.
5.
USE OF OTHER METHODS Licensees may use methods other than those proposed in Revision 1 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.
Except in those cases in which an applicant or licensee proposes or has previously established an acceptable alternative method for complying with specified portions of the l
I NRC's regulations, the methods described in this guide will be used in the evaluation of licensee compliance with the requirements of 10 CFR 50.71(e).
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r CAUTION STATEMENT Licensees are cautioned against possible deletion of information which may be important j
to risk informed evaluation and decision making. Extent of the information which can be deleted without any adverse impact will be visited during efforts related to risk-informing Part 50.
VALUE/ IMPACT STATEMENT A separate Value/ impact Statement was not prepared for this regulatory guide. The Value/ impact Statement that was prepared for and printed with the draft of this guide, DG-1083, in March 1999, is still applicable. That Value/ impact Statement concluded 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. Copies of the Value/ impact Statement are available for inspection or copying for a fee in the NRC's Public Document Room at 2120 L Street NW., Washington, DC, under Draft Regulatory Guide DG-1083. The PDR may be reached by telephone at (202)634-3273 or fax at (202)634-3343.
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NEl 98-03 [ Revision 1]
O Guidelines for Updating Final Safety Analysis Reports june 1999
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ATIACHMENT 2
NEI 98-03 (Rev.1)
June 1999 i,
[This page intentionally left blank.]
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NEI 98-03 (Rev NEl 98-03 [ Revision 1]
Nuclear Energy Institute Guidelines for Updating Final Safety Analysis Reports l
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june 1999 Nuclear Energy institute,1776 i Street N.W., Suite 400, Washington D.C. (202.739.8000)
NEI 9843 (Rev.1)
June 1999
- nf ACIG10WLEDGMElfTS NEI appreciates the invaluable assistance of the FSAR Task Force and Regulatory Process -
Working Group toward development of this guideline.
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Il0TICE Neither NEI, nor any ofits employees, members, supporting organizations, contractors, or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or cornpleteness of, or assume any liability for damages resulting from any use of, any infonnation apparatus, methods, or process disclosed in this report or that such may not infringe privately owned rights.
NEI 98-03 (Rev.1)
June 1999 TABLE OF CONTENTS f
1 INTRODUCTION............................................... i 2 BACKGRO U ND.............................................
3 DEFINITIONS...............................................
4 ROLE OF THE UPDATED FSAR..............................................................
5 SCOPE OF THE UPDATED FSAR........................................................
6 UPDATING FSARs TO MEET 10 CFR 50.71 (e)....................................
7 FREQUEllCY OF PERIODBC UPDATES......................................
8 TREATMENT OF LONG TERM TEMPORARY MODIFICATIONS
................................11 9 TREATMENT OF DISCREPAllCIES BETWEEN THE FACIUTY AllD APPENDIX A: MODIFYING THE UPDATED FSAR APPENDIX B: 10 GR 50.71 fe) i
r NEI 98-03 (Rev.1)
June 1999
-s 1
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y NE198 03 (Rev.1)
June 1999 9
1 INTNODUCTION The pwpase of this document is to provide licensees with guidance for updadag final safety analysis reports (FSARs) consistent with the requirements of 10 CFR 50.71(e), the FSAR update rule. Guidance is also provided in Appendix A for==1dag voluntary modifications to upd='-d FSARs (UFSARs) (i.e., removal, reform =*ing and simplification ofinformation, as appropriate) to improve their focus, clarity and maintainnhility. Figure 1 (page 5) depicts the overall process for upd=dng and modifying the UFSAR.
2 BACIENOUND FSARs originally served as the principal reference document in support of Part 50 license applications. 'Ibe original FSAR described methods for conforming with applicabl regulations and contains the technical information required by 10 CFR 50.34(b),
including "infonnation that describes se facility, presents the design bases and the lim on its operation, and presents the safety analyses of the structures, systems and components and of the facility as a whole." In 1980, the NRC issued the FSAR upd rule,10 CFR 50.71(e), which requires licensees to uodate their FSARs periodically to assure that the information provided is the latest material developed.
hWons in 1996-97 by the NRC,and licensees identified numerous discrepancies between UFSAR information and the actual plant design and operation. These nadinga have raised questions about possible noncompliance with 10 CFR 50.71(c). The indu has developed this guidance in recognition of the importance of the UFSAR, the ne comply with 10 CFR 50.71(e) update requirements, and the need for UFSARs t consistent with the plant design and operation.
3 DEFINITIONS 3.1 COMMISSION REQblREMENTS Commission requirements include regulations, license conditions, technical spec and orders.
3.2 DESIGN BASES Design bases are informarbn that identifies the specific functions to be per structure, system, or component of a facility and the specific values or ranges chosen for ceintrolling parameters as reference bounds for design. These val 1
NE!9843 Otav.1)
June 1999 (1) restraints derived from generally accepted " state-of-the-art" practices for achieving
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functional goals or (2) requiramante derived from analysis (based on calculations and/or mg.-..a) of the effects of a postulated accident for which a structure, system or component must meet its functional goals. (10 CFR 50.2).
Further discussion and examples of design bases are provided in NEI 97-04, Design Bases Program Guidelines.
3.3 -
HISTORICALINFORMATION Historical information is that which was provided in the original FSAR to meet the requirements of 10 CFR 50.34(b) and meets one or more of the following criteria:
.m information that was accurate at the time the plant was originally licensed, but is not intended or expected to be updated for the life of the plant u information tnat is not affected by changes to the plant or its operation a information that does not change with time.
3 3.4 OBSOLETEINFORMATION Obsolete information is information about (1) equipment that has been removed from the plant, (2) organizations, programs or procedures that are no longer in effect and do not meet the definition of historical information, or (3) design information, evaluations and other UFSAR description that no longer apply to the facility.
3.5 ORIGINALFSAR
'Ibe original FSAR is the FSAR submitted with the application for the operating license, as amended and supplemented, and reviewed by the NRC in granting the initial license to operate the facility. Note that for early licensees, the Final Hazards Summary Report performed the role of the FSAR in the licensing process.
3.6 SAFETY ANALYSES Safety analyses are analyses performed pursuant to Commission requirement to demonstrate the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparabh to the guidelines in 10 CFR 50.34(a)(1) or 10 CFR 100.11. Safety analyses are required to be pmWeA in the UFSAR per 10 CFR 50.34(b) or 10 CFR 50.71(c) and include, but are not limited to, the accident analyses typically presented in Chapter 14 or 15 of the UFSAR.
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NEI9843 (Rev.1)
June 1999 a
l 3.7 UFSAR DESCRIFHON
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UFSAR description includes text, tables, diagrams, etc., that provide an understanding of the design bases, safety analyses and facility operation under conditions of normal operation, anticipated operational occurrences, design basis accidents, external events, and natural phenomena for which the plant is designed to function.
1 3.8 UPDATED FSAR
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The updated FSAR (UFSAR) is the original FSAR as updated per the requirements of f
10 CFR 50.7)(e).
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4 ROLE OF THE UPDATED FSAR
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UFSARs provide a description of each plant and, per the Supplementary Information for the FSAR update rule, serve as a " reference document to be used for recumng safety analyses performed by licensees, the Commission, and other interested parties." The UFSAR is used by the NRC in its regulatory oversight of a nuclear power plant, including its use as a reference for evaluating license amendment requests and in the rwtion for and conduct ofinspection activities. For licensees, portions of the UFSAR are used as a reference in evaluating changes to the facility and procedures unde the 10 CFR 50.59 change process. The UFSAR also serves to provide the general publi a description of the plant and its operation.
5 SCOPE OF THE UPDATED FSAR 10 CFR 50.34(b) defined the scope ofinformation required to be submitted in original FSARs and,by extension, the scope of UFSARs as they exist today. While original FSARs expanded greatly over the years as increasingly detailed information waj of new licensecs, the scope given by 10 CFR 50.34(b) provided the common basel all original FSARs.
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In addition to the scope ofinformation contained in the original FSAR, the scope of today's UFSARs includes information added per the FSAR update rule'. Th requires licensees to update their UFSARs to reflect new Commission req the effects of changes to the facility and procedures, safety evaluations and ana new safety issues requeste'd by the Commission.
' The scope of the UFSAR also may be affected by the other NRC requirements, su
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rule requires licensees to supplement their UFSARs as part of the technical informa renewalapplications.
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NE! 98 03 (Rev.'1)
June 1999
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Just as the scope of the original FSAR was detennined by the requirements of 10 CFR O
50.34(b), it follows that the scope ofinformation subsequently added to the original FSAR through the update process should be guided by the requirements used to establish the content of the original FSAR.
10 CFR 50.34(b) contains the following statement of general intent conceming the required content of FSARs submitted as part of original license applications:
The FSAR shall include information that describes the facility, presents the design bases and the limits on its operation, and presents the safety
. analyses of the structures, systems and components and of the facility as a whole.
Subsections (1) through (9) of 10 CFR 50.34(b) further define or amplify this statement of general intent. Certain information required to be included in original FSARs is now controlled in separate licensee documents in accordance with other NRC regulations. For example, the plant technical speci5 cations establish the limits on facility operation, including safety limits; 1imiting safety system settings; and limiting conditions for operation for structures, systems and components. The technical specifications were required as part of the original FSAR under 10 CFR 50.34(b)(6)(vi), but are now controlled separately from the UFSAR per 10 CFR 50.36.
Based on analysis of 10 CFR 50.34(b), UFSAR updaw hould contain the following s
basic types ofinformation concerning new requirements and information developed since the UFSAR was last upda'ad that are required to be reflected in the UFSAR under 10 CFR 50.71(c):
a new or modified design bases a summary of new or modified safety analyses UFSAR description sufficient to permit under=tanding of new or modified a
design bases, safety analyses, and facility operation (as defined in Section 3.7).
4
NEI 98 03 (Rev.1)
June 1999 Figure 1 PROCESS FOR UPDATING AND MODIFYING THE UFSAR UFSAR Update Process UFSAR Modification Process (Per10 CFR 50.71(e))
(See Appendix A) j j
New Requirements, Current Plant / Procedure Changes, UFSAR Content input Safety Evaluatens.
New lasues V
V v
v App 4 App 4 UFSAR ModlRcahon Evaluation UFSAR Content Guidance Update Cruerta 1r v
1r Reformat Update Simptf/ Remove UFSAR UFSAR UFSAR information information informabon Changes v
identify ; av.w.Z., Remove $
and Basis for Removal 1
Submit UFSAR Update Reporting to the NRC O
O O
._____O E
N.
O g
g g
g g
g m
g M
5
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NEI9843 (Rev.1)
June 1999 -
8 BPDATING FSARs TO MEET 10 CFR 50.71 (e) 6.1 WHAT THE REGULATIONS REQUIRE 10 CFR 50.71(c) requires licensees to' periodically update their UFSARs to assure they remain up-to-date such that they accurately reflect the plant design and operation. Per 10 CFR 50.71(c)(4), the UFSAR is required to reflect changes up to a maximum of six months prior to the date that the last update was submitted to the NRC. The 10 CFR 2
50.71(c) requirements concerning the content of upd=*a= are as follows Each person licensed to operate a nuclear power reactor pursuant to the provisions of f 50.21 or 6 50.22 of this part shall update :xriodically, as provided in paragraphs (e)(3) and (4) of this section, tse final safety analysis report (FSAR) originally submitted as part of the application for
' the operating license, to assure that the information included m the FSAR contains the latest material developed. This submittal shall contain all the changes =ca===ry to reflect information and analyses submitted to the j
Commission by the licensee or prepared by the licensee pursuant to i
Commimmion requirement since the enhmi== ion of the original FSAR or, as i
appropriate, the last upd=*ad_ FSAR. He upd=*ad FSAR shall be revised to ine ude the effects of: all changes made in the facility or procedures as described in the FSAR; all safety evaluations performed by the licensee I
either in support of requested license amendmentt of in support of conclusions that changes did not involve an unreviewed safety question; and all analyses of new safety issues i fvausd by or on behsif of the licensee at Comminaion - request. He upd=*ad mformation shall be
)
appropriately located within the FSAR.
The rule does not require that licensees review all the information contained in the UFSAR for each periodic update. Rather, the intent of the rule is that licensees update only those portions that have been affected by licensee activities since the previous update. Per the Supplementary Information provided with the 1980 FSAR update rule, Submittal of updated FSAR pages does not constitute a licensing action but is only intended to provide information. It is not intended for the purpose of re reviewing plants....
The material submitted may be reviewed by the NRC staff but will not be formally approved.
He rule specifies the types of new information that must be evaluated to determine if the UFSAR must be updated to reflect the new information, i.e., new requirements, changes to the facility or procedures, including supporting safety evaluations, and NRC-requested analyses. The following subsections provide guidance for implementing the requirements.
8 In addmon to the update requirements of 10 CFR 50,71(c), the rule also includes certam administrstive and rgf~si-g requirements. The full text of 10 CFR 50.7)(c) is provided in Appendix B to this report.
6
NEI98 03 (Rev.1) kne 1999
' ~
6.1.1 New Regulatory Requirements
.J UFS ARs must be q=*~1 to reflect changes to the facility resulting from new or
==wed~I requirements, e.g., Appendix R, the Station Blackout rule (10 CFR 50.63), the
~
Anticipated Transient Without Scram (ATWS) rule (10 CFR 50.62), or plant-specific orders. As a result of such new requirements, the following information must be incorpoie:ed in the UFSAR, as applicable:
a new or modified designbases r====y of new or modi 6ed safety analyses a
appropriate UFSAR description as defined in Section 3.7 of this guideline.
e If a new NRC requirement does not result in these types ofinformation, the UFSAR does not need to be updated to reflect the new requirement.
6.1.2 Changes to the Facility or Procedures The UFSAR must be updated to reflect the following effects, as applicable, of changes implemented under 10 CFR 50.90 or 10 CFR 50.59, including supporting safety evaluations:
a change requires update of the existing UFSAR information, including
~
m changes to ai*ing design bases, safety analyses or description of Meing structures, systems, components or functions described in the UFSAR a change results in the removal from the plant of SSCs described in the a
UFSAR or the elimination of functions or procedures described in the UFSAR i
a cmp or supporting safety evaluation results in new design bases or safety a
analyses, or associated description, that must be included in the UFSAR.
If a change or supporting safety evaluation does not affect existing UFSAR informat and does not result in new design bases, safety analyses or UFSAR description, the UFSAR does not need to be updated to reflect the change.
6.1.3 Analyses of New SafetyIssues Licensees should evaluate the effects of analyses or similar evaluations performed by licensees in response to plant-specific NRC requests or NRC generic letters or bulle NRC-requested analyses and evaluations must be reflected in UFSAR updates the basis of the results of the requested analysis or evaluation, the licensee determine that the existing design bases, safety analyses or UFSAR description are either not accurate or not bounding or both. The existing design bases, safety analyses and UF description must be updated to reflect the new information, as appropriate.
7
L.
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NE 96 03 (Rev.1).
i
' June 1999 If the NRC-requested analyses or evaluations do not cause any of these effects, no change
,q to the UFSARis required.
m-6.1.4 Update Process Considerations l
Licensees should establish a process to identify the types of new information that must be i
~ evaluated to determine if the UFSAR must be upd='M_ to reflect the new information. To 4
' be consistent with the requirements of the FSAR update rule, the process should include i
sufficient =dmini*ative controls to identify information and analyses submitted pursuant L
to C==i== ion requirements; changes to the facility or procedures; safety evaluations; l
and analyses of new safety issues performed at Commimmion request.
1 In general, controls sufficient to identify information pursuant to Commimmion requirement should focus on changes to NRC regulations, license conditions, orders and technical specifications. He controls for identifying changes to the facility or procedures and safety evaluations should be integrated with existing licensee administrative controls for implementing design and procedure changes, includmg the process used by licensees in preparing, reviewing and approving 10 CFR 50.59 evaluations, ne controls for j
identifying analyses of new safety issues performed at Commimmion request should focus on NRC bulletins, generic letters and analogous plant-specific communications, including I
NRC requests pursur.2t to 10 CFR 50.54(f).
l 6.2 IAVEL OF DETAIL FORFSAR UPDATES I
While not explicitly addressing the level of detail required for FSARs,10 CFR 50.34(b)(2) i.
required that original FSARs include:
... description and analysis of the structures, systems, and components of the facility, with emphasis upon performance rec uirements, the bases, with technical justification therefor, upon which suci requirements have been established, and the evaluations required to show that safety functions will be accomplished, ne description shall be sufficient to permit undereand=g of the system designs and their relationship to safety l
evaluations.
In addition, the Supplementary Information provided with' the 1980 FSAR update rule stated: "The level of detail to be maintained in the UFSAR should be at least the same as originally provided." Thus, existing UFSAR information of a similar nature may provide a guide for deterraining the level of detail for new information to be included in UFSAR upd=w. However, the primary consideration in determining the level of detail for new information is whether upda'M_ information is sufficient to permit understanding of new or modi 6ed safety analyses, design bases and facility operation.
8
g, NEI98-03 (Rev.1)
)
June t999 f
6.3 EXAMPUCS The following examples illustrate the application of the UFSAR update guidance.
j CASE 1: The licensee action is not in ie:res= to a new Cornminion requirement, does not involve a change, safety evaluation or analysis of a new issue, and does not affect
-vidne UFSAR information. Therefore, no update to the UFSAR is required by 10 CFR 50.71(c).
Example Generic Letter 96-01, " Testing of Safety-Related Circuits," requested licensees to conduct a review of Logic System Testing to ensure that all elements of the logic f
i circuits were being adequately tested and met the technical specification surveillance requirement for adequate logic system functional testing.
This generic correspondence did not constitute a new regulatory requiremen did not request a new analysis. Provided the licensee response to Generic Lette 96-01 did not result in a change to the facility or actions that affected avictino I
UFSAR information, no change to the UFSAR is required.
)
j CASE 2: The licensee action responds to a new Comminion requirement or involves
' hange, safety evaluation or analysis of a new issue, and update of the UF c
to change existinginformation.
Example
?
A change to the safety injection system was initiated to address an operabil concern i&ntibA in NRC Bulletin 88-04, " Potential for Safety-Related Pump Loss." An evaluation of safety injection pump minimum-flow lines resulted in a increase in the recommended minimum-flow rate to preclude hydraulic ins at low flow conditions and assure pump operability. As a result of this eva the orifices in the safety injection recirculation lines were modified to prov irmiswd minimum-flow rate for the pumps.
Unlike the generic letter in the example of Case 1, NRC Bulletin 88-04 r that licensees evaluate safety-related pump performance under minimum flo conditions, and the licensee evaluation resulted in a change to the safety recirculation lines. Because sufficient minimum-flow is necessary to ens system is able to perform its intended safety function, the UFSAR associated with the safety injection system should be modi 6ed to include a discussion of the minimum-flow function as it relates to maintaining ope of the safety injection pumps. In some cases, this may entail adding UF discussion of the minimum-flow function where none previously existed.
1 9
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NEI98 03 (Rev.1)
June 1999 q
Iflicensee evaluations requested by Bulletin 88-04 determined the evieting minimum-flow design to be acceptable, no change to the UFSAR is required.
CASE 3: The licensee action responds to a new Commiaaion requirement or involves a change, safety evaluation or analysis of a new issue, and update of the UFSAR is required to reflect newinformation.
Example 10 CFR 50.62 (the ATWS rule) required the installation d a uw mitigation system specific to the type of plant (Westinghouse, Comb wiw. Engineering, etc.). In response to the ATWS rule, the licensee installed new equipment in the facility. An evaluation was performed in accordance with the guidance in Section 6 to determine if update of the UFSAR was required. Because ATWS constitutes new Comminaion requirements for the plant, the design bases and associated description of the new ATWS equipment should be added to the UFSAR.
CASE 4: He licensee action responds to a new Comminzion requirement or involves a change, safety evaluation or analysis of a new issue, and update of the UFSAR is not required.
t Example The NRC issued a new requirement,10 CFR Part 26, requiring licensees to implement a Fitness for Duty Program (FFD). An evaluation was performed in
, accordance with the guidance in Section 6 to deine if update of the UFSAR was required. He FFD program did not result in new or modified safety analyses or design bases. Provided that the UFSAR does not contain security-related information affected by FFD program implementation, no change or addition to the UFSAR is required as a result of the new requirement.
7 FREQUENCY OFItEQUIRED UPDATES As requiid by 10 CFR 50.71(c)(4), licensees are required to submit a periodic UFSAR update annually or within six months after each refueling outage provided the interval between successive updates does not exceed 24 months. Licensees may request an exemption from this requirement from the NRC. For example, the NRC has granted exemptions allowing licensees to submit a single, combined periodic update for multi-unit plants.
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Jae1999 8
TREATMENT OF LONG-TERN TEMPORARY MODIFKATIONS
'Ibe UFSAR is revised periodically to assure that the information reflects the latest material developed. Nevertheless, at any given time there may be a number of temporary plant and/or procedure changes in effect to support corrective actions or other plant activity. Temporary changes in support of plant operations should be restored to the normal plant condition, e.g., consistent with the UFSAR, in a timely manner. For temporary conditions involving safety-related equipment, timely restoration is required by 10 CFR 50, Ap-div B. Per Generic Letter 91-18, Revision 1, temporary conditions subject to App =dir B that exist longer than the next refueling outage are to be explicitly justi6ed as part of tracking documentation.
Because Temporary changes generally abould not be reflected in UFSAR upd-*~
UFSAR information may lag the current plant status by up to 30 months, the UFSAR is an inefficient vehicle for documenting temporary conditions. This would cause licensees to needlessly revise information in the UFSAR that would shortly revert to its prior condition. The result would be a UFSAR that described temporary modifications that are no longer i=*=bd, and the UFSAR would not refit >ct their removal W.II the next periodic update.
Temporary changes are administratively controlled separately from the UFSAR, and the current status of each is tracked to completion. Tracking documantation ensures that plant staff can determine the cunent plant status to support ongoing plant operations, including evaluations prossed under 10 CFR 50.59. For '-i+-y changes subject to 10 CFR 50.59, evaluations are sformed and a summary report is submitted to the NRC in accordance with 10 CFR 50.59(b).
In general, UFSARs should not duplicate the licensee's tracking and myodug of temporary changes. However, the licensee should reflect in periodic UFSAR upd=*~
temporary modi 6 cations meeting both of the following criteria:
The temporary modi 6 cation is expected to be in place throughout the next a
required periodic UFSAR update cycle', or no schedule for removal has been established;and The licensee detennines based on the update guidance in Section 6 that the a
temporary modification should be reflected in the next required UFSAR update.
Temporary modifications reflected in the UFSAR should be clearly identified as distinguish temporary conditions from the permanent plant design and normal i
3 A penodic update cycle is the period between the cutoff dates for new informatio updates, i.e., from six months (maximum) prior to subminal of one update until si next.
I1
NEI9843 (Rev.1)
June 1999 Consistent with licensee configuration control procedures, there may be t--evis-y
^
modi 6 cations reflected in the UFSAR that are not reflected in other perrnanent plant docinnentation.
If corrective action or other work associated with a temporary modi 6 cation results in a per==e hange to the plant as described in the UFSAR, the UFSAR should be upd=*ad c
to reflect the change.
Examples 1.
A t-uyeuuy modification was installed for six months to defeat an alarm that is explicitly discussed in the UFSAR. While the temporary modification affected information contained in the UFSAR, it would not be included in tim periodic update W== the alarm is eWed to be restored to service before the end of the next required periodic UFSAR update cycle.
2.
Temporary cables for an intercom system have been routed through one of the safety-related battery rooms, and the p
=+r# installation is not planned for more than two years. Based on this schedule, and the schedule for the next UFSAR update, the temporary modification is av-ted to be in place until aAer the next UFSAR update cycle. Therefore, the te.inpei-y modi 6 cation should be evaluated per Section 6 of the guideline for inclusion in the next required UFSAR update. Because the modi 6 cation does not affect arMg UFSAR information, and does not result in new safety analyses, design bases or UFSAR description, i
this modification would not be reflected in the next required UFSAR update.
3.
A temporary modi 6 cation was installed for a safety injection accumulator==kaap water pump, and the permanent resolution of the issue will not be implemented for at least two more years. Based on this schedule, and the schedule for the_next UFSAR update, the temporary modification is vad to be in place until aAer the next UFSAR update cycle and should be evaluated per Section 6 of the guidance for inclusion in the next required update. Because the modification affects the existing description of the makeup function for the safety injection accumulators, the UFSAR should be modi 6ed to reflect the temporary modification as part of the next required update.
12
NEI 98-03 (Rev.1)
June 1999 9
TREATMENT OF DISCREPANCIES BETWEEN THE FACIUTY AND THE UFDATED FSAR If the licensee discovers a discrepancy between the facility and its description in the UFSAR, the licensee should address the discrepancy in accordance with its corrective actions program under 10 CFR 50, Appendix B. If evaluation of the discrepancy results in the identification of a nonconforming or degraded plant condition that may impact the operability of the associated structures, systems and components, the nonconforming or degraded condition should be addressed in accordance with Generic Letter 91-18, Revision l'.
If evaluation of the discrepancy determines that the UFSAR is incorrect, a correction should be initiated in accordance with licensee procedures for inclusion in the next UFSAR update.
- 1.icensees also should evaluate nonconforming or degraded conditions for repo:tability pursuant to requirements.
13
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June 1999 n.
[This page intentionally left blank.]
I I
14
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NE! 98 03 (Rev.1) j June 1999
{
APPENDIX A: MODIFYING THE UPDATED FSAR 1
.I A1 INTRODUCTION As diemaad in this guideline,10 CFR 50.71(c) requires that changes and certain new information be incorporated in periodic updates to the UFSAR. As provided in this appendix, the licensee also may initiate voluntary modifications to the UFSAR-unrelated to plant changes or required updates under 10 CFR 50.71(c)-to improve its
)
focus, clarity and maintainability. The following sections provide guidance for reformatting, simplifying and removing existing UFSAR information. While not discussed in this document, licensees also may add information that goes beyond regulatory requirements and guidance to facilitate use of the UFSAR by plant staff or for j
other purposes.
A2 CONTROLIJNG N0DIFICAT10Its TO THE UPDATED FSAR As discussed in the following sections, three types of modifications may be made to'the information in the UFSAR: reformatting, simplification and removal. UFSAR modifications dien=ed in Sections A3 through A5 that are not the result of changes to the plant or procedures do not require evaluation under 10 CFR 50.59, but they should be admini<tratively controlled through a process that has the following attributes:
The licensee process controls what and how information is reformatted, simplified or
)
s
~
removed from the UFSAR.
The licensee process ensures that the UFSAR continues to contain the r===ary m
scope ofinformation as diene-A in Section 5 of this guideline.
As discussed in Section A6, the NRC should be informed ofinformation removed a
from the UFSAR and the basis for the licensee's determination that such info may be removed. This information should be specifically identified to the NRC as part of required UFSAR updates, i.e., in addition to the changed pages and a list o effective pages currently required by 10 CFR 50.71(e).
It is the intent of this guideline to help licensees remove unimportant information m
from UFSARs such as excessive detail, obsolete information, or redundant information. This guideline is not intended to be used to remove important information from UFSARs about features or functions of SSCs that insights from operating experience or probabilistic risk assessments indicate are risk-significant.
The intent that risk-significant information be retained does not preclude removal of obsolete or redundant information, or excessive detail concerning the design or operation of risk-significant SSCs, provided that the action is consistent with the guidance in this Appendix.
Appendix A Page1
l NEl98 03 (Rev.1)
Jams 1999 As~
REFORMATTING OF BPDATED FSAR IEFORMATION Neither 10 CFR 50.34(b) nor 10 CFR 50.71(e) contain requirements on the format of FSARs. Aus the format of the UFSAR is at the option of the licensee, and the licensee may change the format of the UFSAR provided the content of the UFSAR is maintained consistent with these regulations, regulatory guidance committed to by the licensee (e.g.,
Regal-M Guide 1.70), and this guideline. For example, a licensee may elect to d
reformat the UFSAR to more clearly identify the design bases as defined in 10 CFR 50.2.
Historical information provided in the original FSAR may have become out-of-date and is not expected to be used to support current or future plant operations or regulatory activities. Accordingly,it may be yymyriate to refonnat such information to distinguish it from UFSAR information actively maintained by licensees to describe the updad plant design and operation.
By definition, reformatting UFSAR information-such as designating certain information as historical or relocating historical information to an app-Aiv-does not remove that information from the UFSAR. As such, changes the licensee initiates to historical infonnation constitute changes to the UFSAR that must be reported to the NRC per 10 CFR 50.71(c).
Absent an NRC requirement, licensees need not update historical information in UFSARs to reflect minor changes in population data or other such changes in the site environment.
However, licensees should evaluate pa*=+i=11y significant changes in the site environs, e.g., a new natural gas line within the site boundary or a major new industrial facility near the plant site, to detennine if notification of NRC and appropriate update of the UFSAR are required. For example,10 CFR 50.9 tequires licensees to " notify the Comminaion of information identified by the applicant or licensee as having for the regulated activity a significant implication for public health and safety or common defense and security."
Because changes to historical inforrnation as defined in this guideline are generally not exp-ted or required (except possibly to reflect a significant change in the site environs, i
as discussed above), licensee update of such information under 10 CFR 50.71(c) is not expected.
ne followin2 are examples of historical information:
a Descriptionofpre-serviceinspections m Description ofym,pr.tional tests a Description of start-up tests a Description of station organization for initial licensing Comparative plant data provided to support original plant licensing a
Appendix A Page 2
NEI 98-03 (Rev.1)
June 1999 i
i
)
Industry or other data obtained to support or develop the original plant design bases,j a
including that relating to natural or man-made phenomena such as geography, meteorology, hydrology, geology, seismology, population density and nearby facilities (typically in Chapter 2 of the UFSAR)5 Lists of references, figures and submittals relevant only to the original licensing m
proceeding Description of original factory testing of plant equipment, e.g., emergency dieseI a
generators.
Licensees may reformat such historical information by either of the following, or equivalent, methods:
Qualifying information may be designated as historical via clear annotati m
the UFSAR.
Historical information may be relocated to separate volumes or to specially m
designated appendices of the UFSAR.
Reformatting of UFSAR information should be controlled in accordance with Se 4
r SIMPUFTillG UPDATED FSAR lllFORMAT10ll A4 f
Licensees may elect to simplify information contained in the UFSAR to improv focus, clarity and maintainability. As dims =1in the subt.ections below, licensees simplify UFSAR information by removing excessive detail and by using refe
' ther documents where appropriate.
o A4.1 REMOVING EXCESSIVE DETAIL UFSARs contain the scope ofinformation required for the original FSAR by 10 50.34(b) and the additions to that scope required by 10 CFR 50.71(c). Lat applicants included significantly more detailed information in origin earlier applicants. More recent FSARs grew to be 20 to 30+ volumes more detail in certain respects than was absolutely necessary to suppor licensing reviews.
Removal of excessively detailed text and drawings can improve the focus significant descriptive, design bases, operational and analytical info relevant and useful to support current and future operational and regula s While data and information supporting the original plant design bases for natur be designated as historical, the associated design Appendix A Page 3
NEI984(Rev.1)
June 1999 Detailed text and drawings may be removed from the UFSAR to the extent that the
^
information provided eve-In that nace=aary to present the plant design bases, safety
/
analyses and appropriate UFSAR description.
The following types of excessively detailed textual information may be removed from UFSARs, except as indicated by applicable regulatory guidance or NRC Safety Evaluation Reports:
a Desc.riptive information that is not important to providing an understanding of the plant's design and operation from either a general or system functional 3%Tive, e.g., component model numbers a. Design information that is not impocant to the description of the facility or presentation ofits safety analysis and design bases, e.g., component details such as specific motor horsepower ratings for MOVs a Design information that, if changed during the life of the plant, would have no impact on the ability of plant systems, structures and components described in the UFSAR to perform their design basis function (s), e.g., specific HVAC equipment capacity and flow rate information for structures that do not
. contain equipment that performs design basis functions a Analytical information, e.g., detailed calculations, that is not important to providing an underaaAng of the safety analysis methodology, input assumptions and results, and/or compliance with relevant regulatory and industry standards.
Removal of excessively detailed information from the UFSAR shculd be controlled in accordance with Section A2, including reporting to NRC as discussed in Section A6.
A4.2 REPLACING DETAILED DRAWINGS WTTH SIMPLFIED SCHEMATICS Detailed drawings, such as piping and instrumentation diagrams (P& ids), typically contain engineering and component information that goes beyond that appropriate to complement the textual descriptions in the UFSAR and beyond that necessary to aid in understanding of the system design and principal functions. Examples of such information contained in detailed drawings include pipe line numbers, vents and drains, etc.
Simplified schematics may be substituted for detailed drawings under either of the following conditions: (1) the original FSAR contained simplified schematics that the licensee had later replaced with P& ids or other detailed drawings as a matter of convenience, or (2) the original FSAR included detailed drawings, but simplified schematics will be substituted such that they will not result in removal ofinformation required to be in the UFSAR.
Appendix A Page 4
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4 NEl 98-03 (Rev.1)
June 1999 In the first case, licensees may substitute simplified schematics for detailed drawings because simplified schematics were provided in the original FSAR. Returning simplified
/
schematics to the UFSAR would be consistent with the intent of the FSAR update rule that the level of detail of the UFSAR should be at least the same as that provided in the original FSAR.
~
In the second case, the licensee would need to ensure that simplified drawings together with associated UFSAR text continue to provide sufficient understanding of design hases, safety analyses and facility operation. For example, if the licensee determines that design bases or safety analyses information is contained in detailed drawings that is not conveyed by text, tables or other means in the UFSAR, the licensee should incorporate the information into the simplified schematic or other UFSAR information so that the UFSAR continues to contain all necessary information. Substitution for detailed drawings as described in this paragraph should be controlled in accordance with Section A2, including reporting to NRC as discussed in Section A6.
In some cases, UFSAR drawings may contain little or no information that is necessary or important to provide sufficient understanding of a facility's design bases, safety anal or operation. Such drawings may be eliminated completely from UFSARs provided of the following conditions are met:
Inclusion of the drawing in the UFSAR must not be part of an existing j
a licensee commitment to the NRC (e.g., to Regulatory Guide 1.70)
Evi= ting UFSAR text, tables, and other information provide sufficient j
m edar=*=nAing of a facility's design bases, safety analyses and operation or the licensee supplements the existing information to compenute for the removal of the drawing.
Drawings should generally not be removed from the UFSAR where they are helpl j
understanding the textual description of the design or function ofimportant structures, systems and components. When removing drawings from the UFSAR that are maintained as part of other design documents, licensees should consider providing a reference in the UFSAR to the location of the drawing.
A4.3 REFERENCING OTHER DOCUMENTS IN UPDATED FSARs When assessing the presentation of existing UFSAR information (or evaluating information to be added), there may be instances when the information exists in a separate source document and it is preferable to reference, rather than du part of the source document in the UFSAR. Referencing, rather than duplic information in the UFSAR can simplify the presentation and maintenance of UFSA information and, in some cases, avoid the need for duplicative reporting of chan NRC.
Appendix A Page 5
NE 98 03 Otsv.1)
June 1999 There are two basic ways licensees can 14-oce other document = in the UFSAR e
dap== Sag on the nature of the h=nar* and the purpose of the reference. Each is discussed below.
Geners/ References. General references are not considered part of the UFSAR, but are intanded to provide background information or additional detail thatthe reader may refer to in order to learn more about particular material presented in the UFSAR. These may be texts, enviranmantal studies or. technical reports, as well as licensee-contmiled documents such as operating or maintenance procedmes, calculation manuals, etc.
References to such information may be located at specific points in the UFSAR, or they may be listed at the end of UFSAR chapters or in introductory sections.
Licensees may wish to remove excessively detailed, duplicate UFSAR information that is controlled in a separate licensee source document. In some cases, it may be appropriate to provide a brief summary of the detail being removed and/or a general reference to the controlling dennant a an aid to the reader. Unless the referenced source h=nent is "liicuiprated by reference" (as discussed below), referenced information is not part of the UFSAR and would not be subject to 10 CFR 50.71(c), except as specifically committed to by licensees. Replacement of detailed information with a brief summary and/or reference constitutes removal of UFSAR information that must be controlled consistent with guidance in Section A2 and reported to NRC as discussed in Section A6.
Incorporadan by Reference. "Incurycidion by reference" refers to a method by which all or part of a separate source' document can be made part of the UFSAR without i
duplicating the desired information in the UFSAR. Information that is appropriate to include in the UFSAR that is also part of a separate licensee-controlled document or technical report may be incorporated in the UFSAR by appropriate reference to that information. By relying on information "incorpc 44 by reference," licensees may simplify their UFSARs by removing information that is duplicated in separate, controlling program documents such as the Emergency Plan, Offsite Dose Calculation
{
Manual, Fire Protection Plan and Fire Hazards Analysis Report, Security Plan, Environmental Protection Plan and Quality Assurance Plan.
Considerations when incorporating by reference include the following:
Licensees should clearly identify in the UFSAR text the document or portion thereof m
to be incorporated, and state dat the document or portion thereofis " incorporated by reference" in the UFSAR. For example, one option would be to locate in Chapter One of the UFSAR a single section or table that maintains the list of all documents considered incorporated. References should be as clear and specific as possible to avoid misunderstandings about the extent ofinformation incorporated by reference and thus considered part of the UFSAR.
Appendix A Page 6
NEI9803(Rev.1)
June 1999 For information to be incorpo&4 by reference, the information must be publicly a
available (i.e., it must have been submitted to the NRC) unless there exists an explicit
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NRC requ'vement to maintain the information on site. Ftuil-o. ore, information incorporated by reference into the UFSAR is subject to the update and iepudug requirements of 10 CFR 50.71(c) and change controls of 10 CFR 50.59 unless separate NRC change control requirements apply (e.g.,10 CFR 50.54(a)).
Because deanents incorporated by reference in UFSARs are subject to the requirements of 10 CFR 50.71(c) and 10 CFR 50.59 (except where separate NRC requirements apply),
licensees should ensure that such documents are being maintained in accordance with these requirements. D-x+.=ts incorporated by reference containing information that is not required to be in the UFSAR, e.g., by 10 CFR 50.34(b) or 10 CFR 50.71(c), may be appropriately reclassiSed as general references.
I Licensees may control the Technical Requirements Manual and similar licensee controlled documents in either of the following ways:
'Ibe TRM or other licensee controlled document is explicitly " incorporated by a
reference" into the UFSAR. Under this approach, the referenced document is subject to the change control requirements of 10 CFR 50.59 and the update / reporting requirements of 10 CFR 50.71(c), e.g., periodic submittal of change pages, etc.
m The TRM or other licensee cont:olled document is treated in a manner j
consistent with procedures fully or partially described in the UFSAR. Under
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this approach, the ' referenced da ament is maintainad on-site in accordance with licensee admini*ative processes, and changes are evaluated using 10 CFR 50.59.
A5 REMOVING UNNECESSARY INFORMATION FROM UPDATED FSARs Licensees may remove obsolete and radnadant information and commitments from UFSARs. When removing information as described in this section, licensees should follow the guidance in Section A2 for controlling modi 5 cations to the UFSAR and Section A6 for reporting to the NRC.
Obsolere Informarion. Licensees should remove UFSAR information, as appropriate, in connection with removal of SSCs from the plant or elimination of functions or procedures described in the UFSAR. However, licensee review of UFSAR information may identify where this has not occurred, or where removal of UFSAR information in connection with a change was incomplete. In general, licensees should remove from UFSARs des of equipment that is no longer installed in the plant; organizations, programs or procedures that are no longer in effect; and design information, evaluations or ot description that no longer apply to the facility. The exception to this guidance is th Appendix A Page 7
NE!98 03 (Rev.1)
June 1999 programmatic information that was explicitly required under 10 CFR 50.34(b) to be A.
included in original FSARs, e.g., plans for y+.iional testing and initial operations, may not be removed from the UFSAR. Such information is considered historical; e
lim =e= may opt to reformat this information in accordance with Section A3.
Where the presence of obsolete information indicates a dimp.scy between the UFSAR and the actual plant design or operation, the discrepancy should be evaluated in accordance with Section 9 of this guideline.
Organizations, programs and procedures no longer in effect are considered obsolete, as opposed to historical, if they were instituted and included in the UFSAR subsequent to initial plant licensing.
If equipment has been retired in place (equipment that is no longer in service but has not been physically removed from the plant), functional descriptions in the UFSAR that no longer apply to the equipment are considered obsolete information. To accurately reflect the condition of the plant, physical descriptions of equipment retired in place (e.g.,
component and location) in the form of text and/or drawings should be retained in the UFSAR.
RedundastInformadas. Licensees may remove dt plicate information from the UFSAR. If some or all of the duplicated information is important to facilitate unds dag of multiple sections of the UFSAR, the licensee should retain appropriate duplicate information where it is needed. Alternatively, the licensee may remove duplicate information and provide a reference to the location in the UFSAR where the information is to be retained.
4 Comodoments. Some licensees may have incorporated specific commitments made to the NRC within the UFSAR. Consistent with Commission guidance', licensees may remove from the UFSAR commitments that are not integral to required UFSAR irformation, i.e.,
design bases, safety analyses and associated description. Removal from the UFSAR does not change the status or nature of commitments to the NRC. NEl 99-00, Guidelinefor Managing NRC Commitment Changes,' provides guidance for maing changes to NRC commitments.
Licensees should ensure that NRC commitments removed from the UFSAR are included in licensee commitment management or corrective action programs as appropriate. If the licensee committed to the NRC to incorporate a commitment in the UFSAR, then the
' In a Staff Requirements Memorandum dated May 20,1997, the Commission directed the NRC staff to formulate an.py.usch to FSAR updates that would " allow obsolete or less meaningful infonnation and commitments to be readily removed from the FSAR."
' NEI 99-00 was in final draft form at time of publication of this document.
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NEI 98-03 (Rev.1)
June 1999 I
licensee should inform the NRC ofits removal from the UFSAR, consistent with the y
licensee's commitment change pwss.
I A6 REPORTING TO THE NRC INFORMATION REMOVED FROM THE UFSAR J
Information removed from the UFSAR should be specifically identified to the NRC as part of required UFSAR updates. A brief description of the information removed and the basis for its removal should be provided. This information should not be incorporated in the UFSAR but should be provided in addition to the changed pages and a list of effective pages currently required by 10 CFR 50.71(e).
The following are examples of description suitable for notifying the NRC that information was removed from the UFSAR:
a removed model number information for components of the Reactor Equipment Cooling System previously contained in UFSAR Section XYZ on the basis that this was excessively detailed information replaced the P&ID for the auxiliary feedwater system with a simplified a
schematic.
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Appendix A Page 9
e, NEI 98-03 (Rev.1)
June 1999
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APPENDIX B: 10 CFR 50.71fe)
Note: The changes identrRed below to 10 CFR 50.71(e) are expected to be approved by the Commission in connection with rulemaking to amend 10 CFR 50.59 afterpublication of this document.
Each person licensed to operate a nuclear power reactor pursuant to the provisions of 9 50.21 or 9 50.22 of this part shall update periodically, as provided in paragraphs (e)(3) and (4) of this section, the final safety analysis report (FSAR) originally submitted as part of.the application for the operating license, to assure that the information included in the FSAR contains the latest material developed. This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the licensee or prepared by the licensee pursuant to Commission requirement since the submission of the original FSAR or, as appropriate, the last updated FSAR. The updated FSAR shall be revised to include the effects 1 of: all changes made in the facility or procedures as described in the FSAR; all safety analyses and evaluations performed'by the licensee either in support of vestwestodaooroved license amendments or in support of conclusions that changes did not ! :5;: : unt:r!:::: '
'J.; qr::fr reauire a license amendment in accordance with 6 50.59(cM2) of this part: and all analyses of new safety issues performed by or on behalf of the licensee at Commission request. The updated information shall be appropriately located within the uodate to the FSAR.
(1) The licensee shall submit revisions containing updated information to the Commission, as specified in 9 50.4, on a replacement-page basis that is accompanied by a list which identifies the current pages of the FSAR following page replacement.
(2)
The submittal shall include (i) a certification by a duly authorized officer of the licensee that either the information accurately presents changes made since the previous submittal, necessary to reflect information and analyses submitted to the Commission or prepared pursuant to Commission requirement, or that no such changes were made; and (ii) an identification of changes made under the provisions of 9 50.59 but not previously submitted to the Commission.
(3)
(i) A revision of the original FSAR containing those original pages that are still applicable plus new replacement pages shall be filed within 24 months of either July 22,1980, or the date of issuance of the operating license, whichever is later, and shall
' Effects of ch=:es inchidae euvivudate revisions of dMotions in the FSAR such that the FSAR (as uodated) is camnlete and accurate Appendix B Page1
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- NEI98 03 (Rev.1)
June 1999 bring the FSAR up to date as of a maximum of 6 months prior to the date of filing the revision.
(ii) Not less than 15 days before $50.71(e) becomes effective, the Director of the Omce of Nuclear Reactor Regulation shall notify by letter the licensees of those nuclear power plants initially subject to the NRC's systematic evaluation program that they need not comply with the provisions of this section while the program is being conducted at their plant. The Director of the Office of Nuclear Reactor Regulation will notify by letter the licensee of each nuclear power plant being evaluated when the systematic evaluation program has been completed. Within 24 months after receipt of this notification, the licensee shall file a complete FSAR which is up to date as of a maximum of 6 months prior to the date of filing the revision.
(4) Subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months.
The revisions must reflect all changes up to a maximum of 6 months prior to the date of filling. For nuclear power reactor facilities that have submitted the certifications required by $50.82(a)(1), subsequent revisions must be filed every 24 months.
-(5) Each replacement page shall include both a change indicator for the area-changed, e.g., a bold line vertically drawn in the margin adjacent to the portion actually changed, and a page change identi5 cation (date of change or change number or both).
(6)
The updated FSAR shall be retained by the licensee until the Commission terminates theirlicense.
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Appendix B Page 2