ML20211N764

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Notation Vote Approving with Comment SECY-99-203 Re Regulatory Guide for Updated Final Safety Analysis Repts in Accordance with 10CFR50.71(e)
ML20211N764
Person / Time
Issue date: 08/20/1999
From: Dicus G, The Chairman
NRC COMMISSION (OCM)
To: Vietticook A
NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20211N762 List:
References
SECY-99-203-C, NUDOCS 9909130068
Download: ML20211N764 (2)


Text

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NOTATION VOTE RESPONSE SHEET TO: Annette Vietti-Cook, Secretary FROM: CHAIRMAN DICUS

SUBJECT:

SECY-99-203 - REGULATORY GUIDE FOR UPDATED FINAL SAFETY ANALYSIS REPORTS IN ACCORDANCE WITH 10 CFR 50.71(E) w Approved x /commentsDisapproved Abstain Not Participating COMMENTS:

See attached comments.

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Chairman Dicus comments on SECY-99-203, " Regulatory Guide for Updated Final Safety

Analysis Reports in Accordance with 10 CFR 50.71(e)."

l agree with the approach in Regulatory Guide 1.181 and NEl 98-03 (Rev.1) for updates to FSARs, including allowing the removal of selected items that are no longer significant.

While it is important that the NRC has provided guidance, it must be recognized that RG 1.181 and NEl 98-03 are not requirements or licensee commitments, which means that licensees must voluntarily improve their documentation and the processes for maintaining it. Given the lessons leamed from Millstone, I think it important that the NRC continue to cic,se;y monitor industry efforts in FSAR updates and design basis', as discussed in the ' implementation" paragraph of the SECY. I also believe that the Commission should be kept informed of industry trends in these areas, and recommend the following guidance to the staff.

The staff should inform the Commission'of the results ofits prograrn to monitorlicensee efforts to update the FSARs as discussed in the SECY, including an assessment of whether the

. guidance for FSAR updates or design bases or both needs to be modified. As part of this assessment, the staff should consider whether additional inspections or audits of industry practices beyond normal inspection efforts are appropriate.

The' staff should provide the Commission a recommended schedule for this assessment. Since FSAR updates can occur at 24 month intervals, the staff should ensure sufficient FSAR updates are received to be considered a representative sample, but should not wait for FSAR updates to be received from all facilities. Both recently licensed and older facilities should be considered in the sample.

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