ML20247K903
| ML20247K903 | |
| Person / Time | |
|---|---|
| Issue date: | 04/20/1998 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-98-087, SECY-98-087-01, SECY-98-087-R, SECY-98-87, SECY-98-87-1, SECY-98-87-R, NUDOCS 9805220246 | |
| Download: ML20247K903 (52) | |
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POLICY ISSUE April 20, 1998 SECY-98-087 EOR: The Commissioners EROM: L. Joseph Callan Executive Director for Operations SUBJECI:
PROPOSED GENERIC LETTER 98-XX: INTERIM GUIDANCE FOR UPDATED FINAL SAFETY ANALYSIS REPORTS IN ACCORDANCE WITH 10 CFR 50.71(e)
PURPOSE:
To obtain the Commission's approval to issue the proposed generic letter for public comment.
SUMMARY
The staff has developed a proposed generic letter that provides interim guidance for complying with 10 CFR 50.71(e), the " update rule." As requested by the Commission, the proposed generic letter (1) allows the removal of certain information from the updated final safety analysis report (updated FSAR), (2) is applicable to plants undergoing decommissioning, and (3) recommends a partial extension of tb > enforcement discretion period that will result in a risk-informed prioritization of information to be updated to make the updated FSAR complete. The proposed generic letter conforms to existing requirements, an approach that avoids the need to undertake rulemaking pertaining to updated FSARs at this time. Consistent with this approach, the staff considered but did not include in the proposed generic letter guidance on risk-informed content of the updated FSAR.
The staff will ultimately issue a regulatory guide as the long-tenh guidance for updated FSARs.
The staffs preferred approach is for the Nuclear Energy institute (NEl) to revise its draft guidance document, " Draft Industry Update Guidelines for Final Safety Analysis Reports," dated November 14,1997 (NEl 98-03), to conform to the guidance in the proposed generic letter.
The staff could then endorse NEl 98-03 in the regulatory guide.
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Contact:
Thomas Bergman, NRR NOTE: TO BE MADE PUBLICLY AVAILABLE 301-415-1021 WHEN THE FINAL SRM IS MADE AVAILABLE
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The Commissioners l BACKGROUND:
Section 50.34 (10 CFR 50.34), " Contents of Applications; Technical Information," includes 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 $50.34(a). An application for an operating license must include an FSAR in accordance with 950.34(b). For holders of operating licenses,
$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 Regulatory Guide (RG) 1.70, Revision 3,
" Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants, LWR Edition," dated November 1978. Guidance for the format and content of updated FSARs was previously provided in Generic Letter 80-110, " Periodic Updating of Final Safety Analysis Reports (FSARs)," dated December 15,1980, but the guidance in that generic letter was limited.
As a result of lessons leamed from the Millstone experience and of other initiatives related to updated FSARs, the NRC determined that additional guidance regarding compliance with
$50.71(e) was necessary. The staff recommended specific actions in SECY-97-036, " Millstone Lessons Leamed Report, 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 650.71(e) to ensure that updated FSARs 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 50.71(e). The Commission suggested that this guidance include a risk-informed approach for prioritization and content of the updated FSAR, allow removal of certain information from the updated FSAR, and consider whether the period of enforcement discretion regarding updated FSARs should be extended. In j the SRM of March 24,1998, for 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 updated FSARs and further requested that guidance be provided for plants undergoing decommissioning. This current paper responds, in part, to the SRMs of May 20,1997, and March 24,1998, by forwarding a proposed generic letter for the Commission's consideration. If the Commission approves, the generic letter will be issued for public comment for a period of 60 days.
DISCUSSION:
The primary purpose of this paper is to request Commission approval to issue the proposed generic letter for public comment. This paper also (1) provides the staff's basis for not recommending an approach that would result in risk-informed content of updated FSARs at this time, (2) includes the proposed schedule to issue and implement the proposed generic letter, and (3) describes the staff's approach that will result in long-term guidance for the updated FSAR in the form of a regulatory guide.
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The Commissioners Prooosed Generic Letter Attachment 1 is the proposed generic letter, the purpose of which is to provide interim guidance for licensees pertaining to updating their FSARs in accordance with current requirements. As a result of a lack of prior definitive guidance conceming the requirements of the update rule and the absence of detailed staff reviews of the periodic updates, some staff positions regarding
$50.71(e) were neither clearly articulated nor did industry uniformly implement the update rule.
Although the staff positions in the proposed generic letter are consistent with the requirements of the update rule, for some plants they could be considered staff positions applicable to those plants, and therefore considered backfits. Because established regulatory requirements exist but are not being satisfied, these backfits are necessary to bring licensees into compliance with 10 CFR 50.71(e). Therefore, on the basis of 10 CFR 50.109(a)(4)(i), a full backfit analysis was not performed. In accordance with NRC procedures, an evaluation was performed, including a statement of the objectives and the reasons for the requested actions and the basis for invoking the compliance exception, which is provided in the proposed generic letter.
The proposed generic letter includes specific guidance on scope, level of detail, format, removal of information not associated with a change, drawings, historical information, frequency of the periodic updates, temporary modifications, treatment of nonconforming conditions between the facility and the updated FSAR, treatment of FSAR information related to removal of or retirement-in-place of systems structures or components (SSC), and exercise of enforcement discretion regarding complete and accurate updated FSARs. Each of the specific guidance sections are summarized below. Attachment 1 should be reviewed for a more detailed description.
Scope: Since the purpose of the updated FSAR was to keep the FSAR current, the staff views the scope of the FSAR as defined by two regulations: $50.71(e) and 550.34(b).
Section 50.34(b) provides the requirements for the original FSAR. Section 50.71(e) specifies the current information in the updated FSAR that must be changed and the new information that must be added to the updated FSAR.
To determine what information needs to be incorporated into the updated FSAR, the licensee first establishes which changes and analyses meet the test of 10 CFR 50.71(e) to be considered for inclusion in the updated FSAR. The requirements of 50.34(b) are then used to determine whether and to what extent the changes and analyses include any of the four basic types of information required to be in the FSAR (and thus, the updated FSAR): (1) a description of the facility, (2) a presentation of the design bases, (3) the limits on the facility's
The Commissioners operation, and (4) a presentation of the safety analysis of the SSCs and of the facility as a whole. The effect of this approach is that only those analyses and changes that result in a change to or creation of a new (1) description of the facility, (2) design basis, (3) operating limit, or (4) safety analysis need to be included in the updated FSAR! The staff expects licensees to include new analyses and descriptions required by new Commission requirements or performed in response to Commission request. It is not expected that the updated FSAR summarize or refer to every change and analysis conducted by the licensee. Rather, licensees should only incorporate those analyses and changes that belong in a FSAR and, by extension, the updated FSAR; and only to the extent that the analysis or change modifies the existing or creates a new (1) description of the facility, (2) design basis, (3) operating limit, or (4) safety analysis.
Level of Detail: According to the Supplementary information for the update rule, "The level of detail to be maintained in the updated FSAR should be at least the same as originally provided."
Since the level of detail in the original FSARs varies significantly among plants (primarily as a function of the date of the operating license), the updated FSARs may also address similar issues at different levels of detail. The Supplementary Information provided specific guidance for the amount of information to be included for changes made pursuant to
$50.59, which may result in the addition of information by some licensees to the updated FSAR that is more detailed than the information in the original FSAR.
Format: The format of the updated FSAR is at the option of the licensee, and licensees may change the format of the updated FSAR provided that the content of the updated FSAR continues to meet requirements.
Removal ofInformation Not Associated With a Change: If a licensee wishes to remove information from the UFSAR that is not associated with a change, or to relocate the information to other licensee-controlled documents, the licensee is encouraged to develop a process that (1) controls what and how information is removed or relocated, (2) ensures that the updated FSAR continues to contain the necessary information, (3) develops documentation that describes the information removed and the licensee's basis for removing the information from the updated FSARs, and (4) includes this documentation as part of the periodic updates submitted to the NRC. The staff believes that licensees that implement such a process can remove information from the UFSAR that is excessively detailed, less meaningful or redundant or relocate it to other licensee-controlled documents.
Drawings: In general, simplified drawings can be substituted for the reduced piping and instrumentation diagrams (P&lDs) currently in some updated FSARs. The resultant simplified drawings or text of the updated FSAR must contain all necessary information, however, some of the detail and minor components can be removed from the P&lDs. The effect of this guidance is to reduce the scope of $50.59 as changes to some minor components would no 2The four types of information are a simplification of the requirements of @50.34(b) to aid discussion. As described in the " Discussion" section, @50.34(b) identifies nine specific categories of information. Licensees should ensure that they include all the information required by $50.34(b)
The Commissioners longer be required to be evaluated pursuant to $50.59 as they would no longer be "as described in the safety analysis report." Licensees can also substitute full-size P&lDs for the reduced P&lDs as a type of format change.
Historicallnformation: Certain historical information, for example, the initial training program and start-up test program, cannot be removed from the updated FSAR as it is required to be part of an FSAR by $50.34(b). Licensees can relocate the information to separate volumes or to appendices to the updated FSAR. The industry's argument for removing this type of historical information from the updated FSAR has been that maintaining this information is unnecessarily burdensome. However, if the information is, in fact, historical and thus not subject to change, there should be little or no burden associated with this information since neither 50.59 nor the update rule have an effect unless there is a change to the information in the updated FSAR.
Frequency of the Periodic Updates: Licensees are required to submit a periodic update annually or within 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months. For multiple-unit sites with common updated FSARs, this measure requires an update after each unit's refueling outage. Some licensees of multiple-unit sites have obtained exemptions to this requirement such that they are permitted to issue an update for both units linked to a specific unit's outage.
The staff may have provided informal guidance to some licensees indicating exemptions were not necessary for multiple-unit sites with common updated FSARs. To ensure that licensees are on an equal compliance level, licensees for sites with multiple units and a common updated FSAR that currently do not have an exemption will not be subject to enforcement action for failure to meet 10 CFR 50.71(e)(4) if an exemption is issued for exemption requests submitted within 90 days of the issue date of the generic letter.
Temporary Modifications: Licensees should include in the periodic update those temporary modifications for which the licensee (1) has no established schedule to remove the temporary modification, (2) intends to keep the temporary modification in place until after the next periodic update, or (3) intends to eventually change the facility as currently described (i.e., when the temporary modification is removed, a design different from the current design will be installed).
Treatment of Nonconforming Conditions Between the Facility and the Updated FSAR:
Licensees are reminded that guidance on resolution of nonconforming conditions between the facility and the updated FSAR is provided in Generic Letter 91-18, Revision 1, dated October 9, 1997, "Information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions."
Treatment of FSAR Information Related to Removal of or Retirement-in-Place of SSCs: The l guidance in the generic letter is applicable to and can be used by operating plants that remove or retire-in-place SSCs, or change an SSC's functions and by plants undergoing decommissioning. In general, when a system, structure, or component (SSC) is removed from the facility or retired-in-place, the information in the updated FSAR should be revised to remove the information or to clearly note that the SSC no longer performs the functions described in the
The Commissioners updated FSAR. If the functions of the SSC are changed, the updated FSAR should reflect the functions the SSC performs.
Exercise of Enforcement Discretion Regarding Complete and Accurate Upoated FSARs: Under certain conditions the enforcement policy currently allows the staff to grant enforcement discretion with respect to updated FSARs that are not complete and accurate. Licensee efforts to date have been focused on accuracy of information in the updated FSAR as licensees were awaiting guidance from the staff on the content of the updated FSAR (the proposed generic letter). This enforcement discretion period ends October 18,1998. The staff proposes that the current enforcement discretion be modified to account for the proximity of the expected issue date of the proposed generic letter to October 18,1998. For alllicensee efforts related to accuracy of information in the updated FSAR, the staff recommends that the enforcement discretion end as planned on October 18,1998. Regarding completeness of the updated FSAR, the staff proposes a risk-informed update prioritization as requested by the May 20,1997, and March 24,1998, SRMs. To implement this risk-informed prioritization, licensees would use the categorization of SSCs performed as part of their program to comply with the maintenance rule,10 CFR 50.65, using Regulatory Guide 1.160, Revision 2,
" Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," dated March 1997.
For those sections of the updated FSAR containing information that pertains to structures or systems categorized as having high safety significance for purposes of the maintenance rule, licensees must have an updated FSAR that is also comniata within six months of the date of issuance of the final generic letter, if only one or more components in a structure or system is considered to be of high safety significance, the licensee must treat the antire structure or system to which the component belongs as having high safety significance and ensure that all information in the updated FSAR pertaining to the system or structure is complete. For other information in the updated FSAR, licensees must have an updated FSAR that is also complete within 18 months of the date of issuance of the final generic letter.
This approach would build on licensees' efforts to categorize SSCs on the basis of safety significance as part of theirimplementation of the maintenance rule. The staff expects to complete the maintenance rule baseline inspections, including reviews of safety significance categorization, in July 1998. The staff believes that the suggested schedule for extending the enforcement discretion provides sufficient time for licensees to ensure that their updated FSARs are complete. As with the current enforcement discretion, the staff will not exercise discretion if the staff determines that a licensee is not making progress or does not have a program in place to identify and corrcet deficiencies in their updated FSARs by the end of the enforcement discretion period.
If the Commission approves issuing this proposed generic letter, the staff will propose a revision to the enforcement policy prior to the issue date of the generic letter to implement the enforcement discretion described herein.
Risk-Informedfontent and Prioritization in the SRMs of May 20,1997, and March 24,1998, the Commission requested that the staff provide guidance for a risk-informed content and prioritization approach for updated FSARs. As
The Commissioners -7 l
described above, the staff developed a risk-informed prioritization approach in the proposed generic letter; however, the staff has not incorporated guidance that would make the content of l
the updated FSAR risk-informed. The content of the updated FSAR is defined by current regulations and, therefore, reflects the deterministic approach of the current regulations. In order to change to a risk-informed content of the updated FSAR, rulemaking would be necessary, consistent with what was described for the risk-informed framework for Option 5 in SECY-97-205. At this time, such an undertaking for updated FSARs is not considered practical.
Schedule for the interim Guidance j In addition to issuing the proposed generic letter, the staff will also need to revise the enforcement policy, develop inspection guidance for inspectors and other members of the staff, and provide training on the generic letter and inspection guidance. Assuming the Commission approves issuing the proposed generic letter for public comment, the staff proposes the following schedule:
t Elapsed Time, Days Activity Commission approval of generic letter 0 issue generic letter for public comment 30 Receive public comments 90 Complete draft inspection guidance 90 Make draft inspection guidance publicly available 90 Incorporate public comments 120 Public workshop 120 incorporate workshop comments 150 j issue final generic letter 150 lasue revised enforcement policy 150 l Issue final inspection guidance and begin 180 j inspector / staff training implementation date of generic letter 330 Complete inspector / staff training 330 l
The Commissioners Long-Term Gj,udance The NEl has proposed that the draft NEl 98-03 be used as guidance for the updated FSAR.
Although the staff cannot endorse the current NEl 98-03 in all respects without rulemaking, the staff may, in the future, endorse NEl 98-03 if it is modified to conform to the guidance in the proposed generic letter, or if rulemaking occurs such that certain provisions in NEl 98-03 can be endorsed, or some combination thereof. If rulemaking occurs, the staff believes that guidance for complying with existing requirements should be available in the interim (the proposed generic letter), if NEl 98-03 is modified to conform to the guidance in the proposed generic letter such that the staff can endorse NEl 98-03, the regulatory guide that endorses NEl 98-03 will become the guidance and will be consistent with the interim guidance in the proposes generic letter. If NEl 98-03 is not modified and rulemaking does not occur, the staff would reissue the guidance in the proposed generic letter as long-term guidance in the form of a regulatory guide.
The current version of NEl 98-03 cannot be endorsed because it would allow (1) the removal of historical information required to be included in an updated FSAR, (2) the removal of ' obsolete" and "less meaningful" information that may not be allowed by the regulations, and (3) the substitution of simplified schematics for P&lDs without ensuring that the updated FSAR continued to contain all required information. Without incorporating the staff positions in the proposed generic letter, the staff believes that rulemaking would be necessary to endorse the approach in NEl 98-03.
The staff does not believe that rulemaking solely to endorse NEl 98-03 is warranted. Although the guidance in the proposed generic letter would result in the retention of more information in the updated FSAR than NEl 98-03 (particularly regarding historicalinformation), the proposed generic letter does provide licensees considerable flexibility regarding the content of the updated FSAR relative to past staff positions.
The staff does see an important role for NEl 98-03 and believes that it could become the long-term guidance for updated FSARs if it is expanded and modified to conform to the guidance in the proposed generic letter. (The guidance in the proposed generic letter on format, frequency of periodic update submittals, temporary modifications, treatment of nonconforming changes between the facility and the updated FSAR, and plants undergoing decommissioning has no comparable counterpart in NEl 98-03). The staff will encourage the NEl to revise NEl 98-03 such that it can become the detailed implementation guidance. The NRC could then endorse NEl 98-03 in a regulatory guide, similar to the approach taken for the maintenance rule, for which RG 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"
The Commissioners endorses NUMARC 93-01. NUMARC 93-01 provides the detailed guidance for licensees to use when developing their program to comply with the maintenance rule. {
As an example, the proposed generic letter provides the attributes of an approach for removing information from the updated FSAR that is not associated with a change to the facility.
NEl 98-03 could provide a specific process for utilities to use that has the attributes recommended in the proposed generic letter. Licensees that then implement NEl 98-03 would be in compliance with the applicable requirements.
If public comments on the proposed generic letter indicate that rulemaking to endorse the positions in NEl 98-03 is desirable, the staff would reconsider rulemaking to incorporate the appropriate positions in NEl 98-03. If rulemaking is not undertaken to adopt all the provisions in NEl 98-03, and NEl chooses not to modify NEl 98-03 to conform to the guidance in the proposed generic letter, the staff will reissue the proposed generic letter as a regulatory guide. ;
The regulatory guide would contain the same guidance as the generic letter, except the l
enforcement discretion section would be deleted as it would no longer be relevant (i.e., the !
enforcement discretion period would have expired by the time the long-term regulatory guide is issued).
CONCLUSIONS:
i The staff has developed guidance for complying with 10 CFR 50.71(e) that is consistent with i
existing requirements. Although the proposed generic letter does not include guidance for risk-informed content of the updated FSAR as was requested in the SRMs of May 20,1997, and March 24,1998, the proposed generic letter does include a risk-informed update prioritization approach that provides sufficient time for licensees to develop complete and accurate updated FSARs, and will allow licensees to focus resources on the most safety-significant SSCs first.
The proposed approach also avoids the need to undertake rulemaking pertaining to updated FSARs.
The staff will ultimately issue a regulatory guide as the long-term guidance for updated FSARs.
If rulemaking does not occur, the guidance in that regulatory guide would be the same as in the l
proposed generic letter, with the exception of the discussion pertaining to enforcement i
discretion. The staff's preferred approach is for industry to revise NEl 98-03 to conform to the i
guidance in the proposed generic letter, and for the NRC to then endorse NEl 98-03 in the staff's regulatory guide.
RESOURCES:
No additional staff resources are needed beyond those identified in SECY-97-205 (i.e.,1.5-2.0 l full time equivalent (FTE) positions) to issue the proposed generic letter, revise the enforcement l policy, and develop associated inspection guidance. An estimated 1,000 staff members (Headquarters and Regional offices) will receive training on the proposed generic letter and associated guidance. With an average training of eight hours for each staff member, the training effort will require approximately 4.0 FTE, which will come from existing resources estimated for training.
The Commissioners COORDINAllON:
The Office of the General Counsel has no legal objection to this paper and issuance of the proposed generic letter for public comment. The Office of the Chief Financial Officer has reviewed this Commission Paper for resource implications and has no objections.
The staff briefed the Advisory Committee on Reactor Safeguards (ACRS) on December 4,1997, on an earlier draft of the generic letter. The ACRS requested that the staff provide another briefing after the staff has incorporated public comments on the proposed generic letter. The CommiMee to Review Generic Requirements (CRGR) has deferred its
-review until after the expiration of the public comment period on the proposed generic letter.
RECOMMENDATIONS:
The staff recommends that the Commission approve:
- 1. issuance of the proposed generic !etter for public comment.
- 2. the release to the public of this Commission paper and its attachments within 5 business days of the date of this Commission paper.
L. eph Callan
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Ex ive Director for Operations Attachments-
- 1. Proposed generic letter
- 2. Draft NEl guidance pertaining to updated FSARs dated November 14,1997 (NEl 98-03)
Commissioners' completed vote sheets / comments should be provided directly to the Office of the Secretary by COB Tuesday, May 5,1998.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Tuesday, April 28, 1998, with an information copy to the Office of the Secretary. If the paper is of such 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 OCA OGC CIO OIG CFO OPA EDO SECY REGIONS
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ATTACHMENT 1: PROPOSED GENERIC LETTER l
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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555-0001
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NRC GENERIC LETTER 98-xx: INTERIM GUIDANCE FOR UPDATED FINAL SAFETY ANALYSIS REPORTS IN ACCORDANCE WITH 10 CFR 50.71(e)
Addressees All holders of operating licenses for nuclear power reactors.
Purpose The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter to provide interim guidance on current requirements of Section 50.71(e) of Title 10 of the Code of Federal '
Regulations (10 CFR 50.71(e), "the update rule") regarding the periodic updating of the plant- ;
specific updated final safety analysis report (the " updated FSAR"). This generic letter i supersedes the guidance in Generic Letter 80-110, " Periodic Updating of Final Safety Analysis j Reports (FSARs)," dated December 15,1980.
Background
Section 50.34, " Contents of Applications; Technical In ormation," includes requirements for the contents of the applications for construction permits and operating licenses for nuclear power reactors. An application for a construction permit must include a preliminary safety analysis i
report (@50.34(a)). An application for an operating license must include a final safety analysis report (@50.34(b)). For holders of operating licenses, $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 " Guide to the Organization and Contents of Safety Analysis Reports" was issued. The most recent guidance document is Regulatory Guide (RG) 1.70, Revision 3, i
" Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants, LWR Edition." Guidance for the format and content of updated FSARs was previously provided in l
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'RG 1.70, Revision 3, and its predecessors are not requirements, and licensees do not have to comply with the guidance therein unless they have committed to do so.
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t Generic Letter 80-110, but the guidance was limited to questions and answers because the rule was considered " essentially self-explanatory. 2 As a result of lessons learned from the Millstone experience and of other initiatives related to updated FSARs, the NRC determined that additional guidance regarding compliance with S50.71(e) was necessary. The staff recommended specific actions in SECY-97-036, " 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). This generic letter provides that guidance.
In developing this generic letter the staff conducted three public meetings in the fall of 1997 with the Nuclear Energy Institute (NEI) and attended a public workshop on licensing issues (including updated FSARs) sponsored by NEl in January 1998. One purpose of the staff's participation in these meetings and workshop was to solicit public and industry input on what information needed to be in an updated FSAR. In addition, NEl developed draft guidance regarding compliance with $50.71(e), " Draft Industry Update Guidelines for Final Safety Analysis Reports."' in a letter dated November 14,1997, NEl provided the guidance (NEl 98-
- 03) asking the NRC to consider eventually endorsing it. On the basis of a preliminary review, it was concluded that the staff cannot endorse NEl 98-03 in all respects without rulemaking.
Therefore, the staff is issuing this generic letter as interim guidance for complying with 950.71(e). ,
Discussion The requirements for the contents of the PSAR are in @50.34(a). The PSAR must include the principal design criteria, derived from Part 50, Appendix A, " General Design Criteria for Nuclear l Power Plants," and the design bases and describe the relation of the design bases to the I
principal design criteria. Information is also required to show that the final design will conform to the design bases with adequate margin for safety. The purpose of the PSAR is to " provide early and adequate information ...[,) to expedite the processing of construction permit applications ...[, and to] minimize burdensome design changes at the operating license stage resulting from design deficiencies in relation to technical specification requirements."' The PSAR is the principal document upon which the Commission bases a decision to issue a construction permit.
2 Generic Letter 80-110 was not originally issued with a generic letter number, the number was later assigned for retrieval purposes. The generic letter is a letter from Darrell G. Eisenhut, Director, Division of Licensing, to All Operating Reactor Licensees, dated December 15,1980, on the subje :t of " Periodic Updating of Final Safety Analysis Reports (FSARs)."
l 3 l At the time of the November 14,1997, submittal, NEl had not assigned a document number to the draft guidance. NEl subsequently informed the staff that the guidance document would be l NEl 98-03, which is how the draft guidance is referred to elsewhere in this generic letter, j l d33 FR 186 iO, December 17,1968, " Technical Specifications for Facility Licenses; Safety Analysis Reports."
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l- The requirements for the contents of the FSAR are in 550.34(b), which states: I Each application for a license to operate a facility shall include a final safety analysis report. The final safety analysis report shall include information that describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components and of the facility as a whole, and shallinclude the following:
(1) All current information, such as the results of environmental and l
meteorological monitoring programs, which has been developed since issuance '
of the construction permit, relating to site evaluation factors identified in part 100 of this chapter. l l
(2) A description and analysis of the structures, systems, and components of the facility, with emphasis upon performance requirements, the bases, with technical justification therefor, upon which such requirements have been established, and the evaluations required to show that safety functions will be accomplished. The i
description shall be sufficient to permit understanding of the system designs and !
their relationship to safety evaluations.
(i) For nuclear reactors, such items as the reactor core, reactor coolant system, instrumentation and control systems, electrical systems, l containment system, other engineered safety features, auxiliary and '
emrgency systems, power conversion systems, radioactive waste handling systems, and fuel handling systems shall be discussed insofar as they are pertinent.
(ii) For facilities other than nuclear reactors, such items as the chemical, physical, metallurgical, or nuclear process to be performed, l
instrumentation and control systems, ventilation and filter systems, electrical systems, auxiliary and emergency systems, and radioactive waste handling systems shall be discussed insofar as they are pertinent.
1 (3) The kinds and quantities of radioactive materials expected to be produced in the operation and the means for controlling and limiting radioactive effluents and radiation exposures within the limits set forth in part 20 of this chapter.
l (4) A final analysis and evaluation of the design and performance of structures, systems, and components with the objective stated in paragraph (a)(4) of this section and taking into account any pertinent information developed since the submittal of the preliminary safety analysis report. Analysis and evaluation of ECCS cooling performance following postulated loss-of-coolant accidents shall be performed in accordance with the requirements of $50.46 for facilities for which a license to operate may be issued after December 28,1974.
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(5) A description and evaluation of the results of the applicant's programs, including research and development, if any, to demonstrate that any safety questions identified at the construction permit stage have been resolved.
(6) The following information concerning facility operation:
(i) The applicant's organizational structure, allocations or responsibilities and authorities, and personnel qualifications requirements.
(ii) Managerial and administrative controls to be used to assure safe operation. Appendix B," Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," sets forth the requirements for such controls for nuclear power plants and fuel reprocessing plants. The information on the controls to be used for a nuclear power plant or a fuel reprocessing plant shallinclude a discussion of how the applicable requirements of appendix B will be satisfied.
(iii) Plans for preoperational testing and initial operations.
(iv) Plans for conduct of normal operations, including maintenance, surveillance, and periodic testing of structures, systems, and components.
(v) Plans for coping with emergencies, which shall include the items specified in Appendix E.
(vi) Proposed technical specifications prepared in accordance with the requirements of $50.36.
(vii) On or after February 5,1979, applicants who apply for operating licenses for nuclear power plants to be operated on multiunit sites shall include an evaluation of the potential hazards to the structures, systems, and components important to safety of operating units resulting from construction activities, as well as a description of the managerial and administrative controls to be used to provide assurance that the limiting conditions for operation are not exceeded as a result of construction activities at the multiunit sites.
(7) The technical qualifications of tha applicant to engage in the proposed activities in accordance with the regulations in this chapter.
(8) A description and plans for implementation of an operator requalification program. The operator requalification program must as a minimum, meet the requirements for those programs contained in 655.59 of part 55 of this chapter.
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(9) A description of protection provided against pressurized thermal shock events, including projected values of the reference temperature for reactor vessel beltline materials as defined in 550.61 (b)(1) and (b)(2).
The principal purpose of the FSAR is to inform the Commission of the nature of the facility, the plans for its use, and the evaluations that have been performed to evaluate whether the facility has been constructed and will operate without undue risk to the public health and safety5 The FSAR is the principal document upon which the Commission bases a decision to issue an operating license and is, as such, part of the licensing basis of the facility. It is also used by NRC inspectors to determine whether the facility has been constructed in accordance with and is operating within the license.
The requirements for the updated FSAR are in $50.71(e), which states:
Each person licensed to operate a nuclear power reactor pureuant to the provisions of $50.21 or 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 of: all changes made in the facility or procedures as described in the FSAR: all safety evaluations performed by the licensee either in support of requested license amendments or in support of conclusions that changes did not involve an unreviewed safety que: tion; and all analyses of new safety issues performed by or on behalf of the lice.nsee at Commission request. The updated information shall be appropriately located within the FSAR.
(1) The licensee shall submit revisions containing updated information to the Commission, as specified in 550.4, 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 shallinclude (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 $50.59 but not previously submitted to the Commission.
5 RG 1.70, Revision 3, ii-iii.
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(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 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 Office 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 drav.n in the margin adjacent to the portion actually changed, and a page change identification (date of change or change number or both).
(6) The updated FSAR shall be retained by the licensee until the Commission terminates their license.
The purpose of the updated FSAR is to " provide an updated reference document to be used in recurring safety analyses performed by the licensee, the Commission, and other interested parties."' The Supplementary Information for the update rule further states:
The initial revision to be filed should contain those pages from the originally submitted FSAR that are still applicable plus new replacement pages that appropriately incorporate the effects of supplements, amendments and other changes that have been made. This will result in a single, complete document being filed that can then serve as the baseline for future changes.
645 FR 30614, May 9,1980," Periodic Updating of Final Safety Analysis Reports."
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l Subsequent periodic updates are to ensure that the updated FSAR remains current and addresses the appropriate licensing issues.
Thus, there is a difference between the PSAR and FSAR, versus the updated FSAR. The l content of the PSAR and FSAR are established by 50.34, which sets forth the information and l analyses that the applicant must submit in support of its construction permit and license application. Therefore, the PSAR and FSAR are the principal technical bases for issuing the construction permit and operating license, respectively. By contrast, submission of updates to the FSAR under the update rule are not in furtherance of a specific licensing action, nor is the submission intended to be part of a periodic NRC re-review of the adequacy of the facility.7 The licensee is not required by the update rule to perform any specific analysis.' Rather, the updated FSAR is intended to be a complete and accurate reference document describing the facility, its procedures, and the supporting bases thereof, in order to facilitate staff safety evaluations (including safety evaluations for requests for license amendments, reliefs and exemptions), staff inspections of the facility to determine whether the facility has been constructed and is being operated in accordance with Commission requirements, the facility's license, and applicable orders.'
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7 The Supplementary information states:
1 The rule is only a reporting requirement to insure that an updated FSAR will be !
available. 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 . Thus, for example, approvals of license l amendments and technical specification changes are independent of the FSAR updating process and once approved would not be subject to further consideration simply because the FSAR is updated . The material submitted may be reviewed by the NRC staff but will not be formally approved.
8This point is emphasized in the Supplementary information:
No analyses other than those already prepared or submitted pursuant to NRC requirements (either originally with the application, or as part of the operating license review process, or as required by $50.59 or other NRC requiren1ent, or to support license amendments) are required to be performed by the licensee because of this rule.
Therefore, the updated FSAR is only changed as a result of other activities by the licensee, '
such as new analyses performed on the licensee's initiative or in response to a Commission requirement or request.
'As the Supplementary Information states, keeping the updated FSAR up to date is important because: "The new pages will be accepted as representing the licensee's position at the time of submittal and will be utilized in any subsequent reviews or NRC staff activities conceming that facility."
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t Guidance A number of issues addressed in this generic letter were identified during the public meetings with NEl held in the fall of 1997, the January 1998 public workshop, and a review of the draft NEl 98-03. Specific guidance is provided on scope, level of detail, format, removal of information not associated with a change, drawings, historical information, frequency of the periodic update submittals, temporary modifications, treatment of nonconforming conditions between the facility and the updated FSAR, treatment of FSAR information related to removal of or retirement-in-place of systems, structures, or components (SSCs), and exercise of enforcement discretion regarding complete and accurate updated FSARs.
Scope Section 50.71(e) provides specific requirements for the scope of issues to be addressed in the periodic updates. As described above, $50.71(e) requires that the updated FSAR contain the latest material developed conceming: (1) 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; (2) the effects of all changes made in the facility or the procedures as described in the updated FSAR; (3) the effects of all safety evaluations performed by the licensee either in support of requested license amendments or in support of conclusions that changes did not involve unreviewed safety questions; and (4) the effects of all analyses of new safety issues performed by or on behalf of the licensee at the Commission's request. In summary, the periodic updates are to include changes to existing information and add the appropriate information for new issues such that the updated FSAR remains complete and accurate.'"
Two rules define the content of the updated FSAR: 650.34(b), which provides the requirements for the original FSAR, and 950.71(e), which specifies the current information in the updated FSAR that must be changed and the new information that must be added to the updated FSAR.
Section 50.34(b) is used as a screen to establish what pordon of the information to be considered for incorporation into the updated FSAR pursuant to $50.71(e) is expected to apoear in the updated FSAR (i.e., the updated FSAR should address the same issues that a current original FSAR would address).
To determine what information needs to be incorporated into the updated FSAR, the licensee first establishes which changes and analyses meet the test of 10 CFR 50.71(e) to be considered for inclusion in the updated FSAR. The requirements of $50.34(b) are then used to determine whether and to what extent the changes and analyses include any of the four basic types of information required to be in the FSAR (and thus, in the updated FSAR): (1) a description of the facility, (2) a presentation of the design bases, (3) the limits on the facility's operation, and (4) a presentation of the safety analysis of the SSCs and of the facility as a
" Complete" means that the updated FSAR includes allthe issues that should have been included in the updated FSAR as required by the update rule since the original FSAR was issued. " Accurate" means that all the differences between the information in the current version of the updated FSAR and the facility, procedures and experiments have been corrected.
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whole. The effect of this approach is that only those analyses and changes that result in a change to or creation of a new (1) description of the facility, (2) design basis, (3) operating limit, or (4) safety analysis need to be included in the updated FSAR." The staff expects licensees to include new analyses and descriptions required by new Commission requirements or performed in response to Commission request. It is not expected that the updated FSAR summarize or refer to every change and analysis conducted by the licensee. Rather, licensees should only incorporate those analyses and changes that belong in a FSAR and, by extension, l
in the updated FSAR; and only to the extent that the analysis or change modifies the existing or creates a new (1) description of the facility, (2) design basis, (3) operating limit, or (4) safety analysis.
In implementing $50.71(e), licensees should incorporate the latest information (description, l design basis, etc.) developed pursuant to each of the specific requirements in the update rule. I
- 1. All the changes necessary to reflect information and analyses subm.1ted to the Commission by the licensee or prepared by the licensee pursuant to Commission requirement.
Where the licensee has submitted information and analyses (e.g., the periodic report required by 550.59(b)(2)) such that the information and analyses in the updated FSAR are no longer accurate, the licensee should correct the information and analyms to reflect the current condition. Where information and analyses in the updated FSAR have become inaccurate as a result of licensee actions pursuant to a Commission requirement,52 the licensee should revise the updated FSAR to reflect the changes that have occurred. In addition, where the underlying l Commission requirement has not changed, but the licensee has undertaken actions that has resulted in the information and analyses required to be in the updated FSAR being incomplete l
and/or inaccurate, the licensee should revise the updated FSAR to ensure that the updat?d FSAR is complete and accurate. As noted in the Supplementary information for the update rule, i changes should be incorporated into the updated FSAR after the changes have been approved for use (by the licensee, or by the NRC where required) and are in effect.
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- 2. The effects of all changes made in the facility orprocedures as described in the updated FSAR.
The update rule does not require licensees to review all the information in the updated FSAR for each periodic update; as noted in the " Discussion," above, the update rule is a reporting requirement and does not require licensees to verify the accuracy of the content of the entire updated FSAR. This point is emphasized in the Supplementary informetn:
"The four types of information are a simplification of the requirements of $50.34(b) to aid discussion. As described in the " Discussion" section, S50.34(b) identifies nine specific l categories of information. Licensees should ensure that they include all the information required by $50.34(b) 12" Commission requirement" refers to regulations, license conditions, technical specifications, and orders.
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Analyses existing in the [ updated] FSAR which are known to be inaccurate or in error as a result of new analyses performed by the licensee pursuant to NRC requirements, would have to be revised. Specialized studies provided in the FSAR, such as on volcanic hazards or quality assurance, should include the latest information developed that has been developed in response to NRC requirements . . Minor differences between actual and projected population figures or other such changes in the site environment need not be reported unless the conclusions of safety analyses relative to public health and safety are affected and the licensee has prepared new analyses as a result of NRC requirements [ emphasis added].
Therefore, the update rule does not require that licensees periodically verify the entire contents of the updated FSAR. Rather, licensees only update those portions that have been affected as the result of licensee activities addressed by Commission regulations." In practic' e, since the preponderance of information in the FSAR (and therefore the updated FSAR) was necessary to demonstrate compliance with requirements, most information in the updated FSAR will need to be maintained up to date.
- 3. The effects of all safety evaluations performed by the licensee eitherin support of requested license amendments orin support of conclusions that changes did not involve an unreviewed safety question.
The periodic update should incorporate changes and new information as a result of license amendments, or changes and new information nade pursuant to 650.59."
- 4. The effects of all analyses of new safetyissues performed by or on behaliof the licensee at Commission request.
The periodic updates must include the effects of analyses of new safety issues performed by or on behalf of the licensee at Commission request. Analyses of new safety issues conducted at
" Pursuant to $50.9(b), licensees are required to " notify the Commission 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." Information in the updated FSAR that becomes inaccurate as a result of such a discovery is required to be included in the periodic update.
"Some licensees may implement $50.59 in a broader context than required (i.e., some licensees evaluate changes other than those "as described in the [ updated final] safety analysis report' as required by $50.59(a)). The effects of the safety evaluations conducted for changes that are outside of the required scope of $50.59 are not required to be included in the periodic update unless they make information in the updated FSAR inaccurate.
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I the request of the Commission can include issues discussed in plant-specific letters, generic letters, and bulletins."
LeveLof_ Detail l
l The update rule does not identify a specific level of detail for the updated FSAR. The level of detailis discussed in the Supplementary information. The Supplementary Information states
! that "The level of detail to be maintained in the updated FSAR should be at least the same as l
originally provided." Since the level of detailin the original FSARs varies among plants
' (primarily as a function of the date of the operating license), the updated FSARs may also address similar issues at different levels of detail.
Section 50.34(b) provides the minimum level of detail required for the information in the FSAR (and thus the updated FSAR). For the SSCs of the facility, for example, @50.34(b)(2) requires
"[a] description and analysis of the [SSCs) of the facility, with emphasis upon performance requirements, the bases, with technicaljustification therefor, upon which such requirements have been established, and the evaluations required to show that safety functions will be accomplished. The description shall be sufficient to permit understanding of the system designs and their relationship to safety evaluations."
l Licensees must ensure that the updated FSAR contains at least the minimum level of detail required by $50.34(b).
One area where more specific guidance was provided in the Supplementary Information is changes to the updated FSAR as result of changes made in accordance with $50.59.
Paragraph 50.59(b)(2) requires licensees to periodically submit a report that contains "a brief i
description of any changes, tests, and experiments, including a summary of the safety evaluation of each." The Supplementary Information for the update rule states that "The l
$50.59(b) reporting may not be detailed sufficiently to be considered adequate to fulfill the '
[ updated] FSAR updating requirement. The degree of detail required for updating the (updated]
FSAR will be generally greater than a 'brief description' and a ' summary of the safety evaluation.'" Therefore, the level of detail in the periodic updates for changes made pursuant to 50.59 should include a description of each change and, at a minimum, a discussion of the basis for the conclusion that the change does not constitute an unreviewed safety question (i.e.,
a simple negative restatement of the requirements of $50.59(a)(2) would be insufficient). For some licensees, this may result in adding information to the updated FSAR that is more detailed than the information in the original FSAR.
The most recent staff position on the content of the FSAR (and therefore the updated FSAR) is in RG 1.70, Revision 3. Licensees are not required to comply with the guidance in the "In some cases generic letters and bulletins are issued under the authority of $50.54(f) or 2.204, or 182 of the Atomic Energy Act. For those cases the licensee's analyses are performed in respor.se to Commission requirement.
I1
regulatory guide; however, the regulatory guide may be used as a reference for an appropriate amount of information to be provided on specific issues.
Format Section 50.71(e) does not specify a format for the updated FSAR. The Supplementary Information states, "The format to be used for the (updated] FSAR revisions is the option of the licensee, but the Commission expects that the format will probably be the same as the format of the original FSAR." Therefore, licensees have the option of changing the format provided the content of the updated FSAR continues to meet requirements.
Removal of information Not Associated With a Chance The update rule provides requirements for changing information in the updated FSAR as a result of new analyses or changes to the facility or procedures. Neither the update rule nor its Supplementary Information address the removal of information from the updated FSAR that is l not associated with a new analysis, or a change to the facility or procedures!' While the I removal of information from the updated FSAR that is not associated with a change is not
! recommended, the staff recognizes that some licensees have removed information from the updated FSAR. Although the regulations do not explicitly prohibit the removal of information not associated with a change, licensees do so at their own risk. If a licensee removes information from the updated FSAR that is not associated with a change, or relocates information to other licensee-controlled documents, the licensee is encouraged to adopt an approach that has the following attributss:
- The licensee has a process that controls what and how information is removed or relocated.
1 The licensee is responsible for ensuring that the updated FSAR continues to contain the necessary information. In particular, the licensee must not remove any information required to demonstrate compliance with 50.34(b), or subsequently required to be added or modified in accordance with 50.71(e).
As part of the periodic updates issued in accordance with 50.71(e), the licensee should submit, in addition to the changed pages and a list of effective pages currently required by 50.71(e), a description of the information removed, and the basis for the licensee's I determination that such information may be removed from the updated FSAR.
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1 The licensee removes information from the updated FSAR at its own risk. If, after removing information from the updated FSAR, a licensee makes a change to the facility that would have i
resulted in a determination that the change was an unreviewed safety question but did not (no
'6lf a new analysis or a change to the facility or procedures makes the content of the updated FSAR inaccurate, the inaccurate information should be removed. For example, if an SSC has been removed from the facility the updated FSAR should be modified to delete reference to that SSC or clearly indicate that the SSC has been removed.
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50.59 evaluation having been performed since the facility was no longer "as described" in the updated FSAR), the licensee would potentially be subject to enforcement. Under the current enforcement policy, such violations would be considered for categorization as a Severity
, Level 111 violation.
An example of information that may be removed that is not associated with a change is redundant information. Licensees may remove duplicaM information from the updated FSAR provided appropriate references are made to the remaining location where the information is discussed in the updated FSAR. Another kind of information that may be considered for removal without an associated change is described below in " Drawings."
Drawinas Updated FSARs typically contain either simplified schematics or reduced-size piping and l
instrumentation diagrams (P&lDs). Two issues have arisen concerning drawings: (1) substitution of full-size P&lDs for reduced-size P&lDs, and (2) substitution of simplified schematics for reduced-size P&lDs.
The substitution of full-size P&lDs for reduced P&lDs is an example of a change in format, which as stated above is at the option of the licensee. The licensee could funher reformat the updated FSAR by relocating the full-size P&lDs to an appendix or separate volume in the updated FSAR (with appropriate references).
The wbstitution of simplified schematics for P&lDs is more complicated because under certain circumstances this substitution would constitute a reduction in the level of detail. As noted above, the Supplementary Information states that the level of detail should be at least that of the original FSAR. In many cases, however, licensees may have incorporated P&lDs into the FSAR or updated FSAR as a matter of convenience rather than to provide required information.
In general, substitution of simplified schematics would be acceptable under either of the following conditions: (1) the original FSAR contained simplified schematics that the licensee had later replaced with P&lDs as a matter of convenience, or (2) the original FSAR included P&lDs but simplified schematics will be substituted such that they will not result in removal of information required to be in the updated FSAR.
in the first case, the substitution of simplified schematics would be acceptable because the update rule only requires that the level of detail of the updated FSAR be at least the same as that in the original FSAR. If simplified schematics were originally provided, retuming simplified 1
schematics to the updated FSAR would be consistent with this requirement.
In the second case, the hensee would need to ensure that no material descriptive information I was lost and that the P&lDs do not contain any unique design basis, operating limits, or safety l analysis information required to be in an updated FSAR. If the licensee determines that a P&lD i
does contain such information, the licensee should incorporate the information in the simplified schematic or relocate the information to the text of the updated FSAR so that the updated FSAR continues to contain all necessary information. When substituting simplified schematics for P&lDs as described in this paragraph, licensees should follow the guidance for " Removal of Information Not Associated With a Change."
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Histodcattnformation Some licensees have asked whether information no longer applicable to an operating plant, e.g., the initial training program and start-up test program, can be removed from the updated FSAR. This question was previously addressed in Generic Letter 80-110, which stated, "Information pertaining to programs described in the original FSAR with amendments, such as the initial training program and the preoperational test program, should be submitted as part of the initial updated FSAR for completeness."
As described in " Scope," the updated FSAR is expected to contain the information required by
$50.34(b), updated to reflect the current facility. Some programmatic information that would now be considered historical is explicitly required to be in an FSAR (such as the initial test program, which is explicitly required by 9 50.34(b)(6)(iii)). Therefore, it is not permissible to remove " historical
- information that is explicitly required to be included in an FSAR. Licensees may, however, reformat the updated FSAR to relocate this type of information to separate volumes or appendices to the updated FSAR. The staff believes that the burden associated with the retention of required " historical" information to be minimal."
Ereguency_of the Periodic _ Update _S.ubmittals The update rule requires in @50.71(e)(4) that licensees submit periodic updates 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 [ filing]. For nuclear power reactor facilities that have submitted the certifications required by
$50.82(a)(1), subsequent revisions must be filed every 24 months.
Some licensees of multiple-unit sites with common updated FSARs have asked whether they need to update the updated FSAR after each unit's refueling outage or whether a combined periodic update can be submitted for all units with the common updated FSAR. The rule is clear that a periodic update must be submitted annually or within six months of each refueling outage. Therefore, unless the combined periodic update is submitted on an annual basis, or (due to refueling outage schedules) within six months of all the units' outages, additional updates are required by the rule.
"The industry argument for removing historical programs has been that maintaining this information in the updated FSAR is unnecessarily burdensome. If the information is, in fact, historical and thus not subject to change, there should be little or no burden associated with this information since neither @50.59 nor @50.71(e) have an effect unless there is a change to the information.
"The original final update rule required the periodic updates to be submitted "no less frequently than annually." The frequency of the periodic updates was amended in 1992. See 57 FR 39353, August 31,1992, " Reducing the Regulatory Burden on Nuclear Licensees."
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On the August 31,1992, rulemaking to reduce regulatory burden that, in part, reduced the frequency of the periodic updates required by SSO.71(e)(4), a public comment was received that requested that the update rule be modified to allow multiple-unit sites with common updated FSARs to submit combined periodic updates. In the Supplementary Information for the August 31,1992, rulemaking, the NRC did not incorporate the requested change, but noted that
" licensees will have maximum flexibility for scheduling updates on a case-by-case basis." In this regard, the staff has granted a number of exemptions to this requirement of the update rule to allow multiple-unit sites with common updated FSARs to submit a combined periodic update at a reduced frequency similar to the frequency for single unit sites (typically by linking the submittal date to a specific unit)."
The phrase "after each refueling outage" is not defined. The date is generally assumed to be that consistent with industry practice: the date the licensee closes the main generator output breakers to reconnect the plant to the grid, if a licensee traditionally uses another date to indicate the end of a refueling outage, the license may use the alternative date.
The rule states that the revisions must be filed six months after each refueling outage. This statement was not intended to mean exactly six months, but rather within six months.
Temporary _ Modifications Neither the update rule nor its Supplementary information explicitly address whether temporary modifications need to be included in the periodic updates. Since the update rule does not distinguish between a change and a temporary modification, a conservative approach would be to include all temporary modifications installed at the time the periodic update submittal is deve!cped so as to ensure that the updated FSAR contains the latest information. The staff believes that such an approach would impose an unnecessary burden on licensees to needlessly revise information in the updated FSAR that would shortly revert to its prior condition, and result in an updated FSAR that described temporary modifications that are no longer installed (and the updated FSAR would not reflect their removal until the next periodic update). Therefore, analogous to the guidance in Generic Letter 91-18, Revision 1, dated October 9,1997, *information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions," temporary modifications that are intended to be installed for only a limited period would not be deemed to be " changes" requiring inclusion in the periodic updates. However, consistent with the intent of the update rule, the licensee should include in the updated FSAR those temporary modifications for which the licensee (1) has no established schedule to remove the temporary modification, or (2) intends to keep the temporary modification until after the next periodic update, or (3) does not intend to restore the facility to its condition as described in the current version of the updated FSAR (i.e.,
a new design will replace the temporary modification).
"The staff may have provided informal guidance to licensees indicating exemptions were not necessary. To assure that licensees are on an equal compliance level, licensees for sites with multiple units and a common updated FSAR that presently do not have an exemption will not be subject to enforcement action for failure to meet 10 CFR 50.71(e)(4) if an exemption is issued for exemption requests submitted within 93 days of this generic letter.
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Ireatment oLNonconforming.ConditionsEetweenlhe_Eacility_and thelpdatedfSAR If the licensee discovers a nonconforming condition between the facility and the description of the facility in the updated FSAR, the licensee needs to address the nonconforming condition in accordance with the guidance in Generic Letter 91-18, Revision 1.
IreatmentoLESAR InformationRelatedloRemovalofractirement-in-Place _oLSSCs This approach is applicable to operating plants that have removed or retired-in-place SSCs, or changed the functions of SSCs and to plants undergoing decommissioning, i.e., those nuclear power reactors whose licensees have submitted certifications pursuant to 10 CFR 50.82(a)(1).
When a plant removes an SSC from the facility, the information concerning that SSC should be removed from the updated FSAR or the information should be clearly marked to note that the SSC has been removed. If an SSC is permanently removed from service or retired-in-place, or no longer performs its original functions (but may now provide new functions), the updated l
FSAR should be updated to indicate that the SSC has been removed from service or retired in place, and should include the functions that the SSC now performs (i.e., description, design basis, operating limits, and safety analysis) as appropriate. At a minimum, the updated FSAR for an SSC permanently removed from service or retired-in-place should continue to provide a basic description of the physical components and layout of the SSC (including relevant drawings) such that it provides an understanding of the equipment that remains installed in the facility and demonstrates compliance with any applicable NRC requirements for that equipment.
Licensees must ensure that the updated FSAR continues to provide all required information notwithstanding the status of SSCs in the facility.
Exercise of Enforcement Discretion Regarding_ Complete and AccurateWpdatedfSARs l
Under certain conditions, the enforcement policy currently allows the staff to grant enforcement l
discretion with respect to updated FSARs that are not complete and accurate. As stated in the Policy Statement, dated October 18,1996,2 Enforcement action would normally not be taken against a licensee if the l licensee identifies violations up to and including Severity Level ll associated with l the [ updated] FSAR by a voluntary initiative (including either a formalinitiative or informal effort where issues are identified through a questioning attitude of an employee), provided the licensee takes comprehensive corrective action and appropriately expands the scope of the voluntary initiative to identify other failures with similar root causes . . [L]icensees should be designing and implementing their programs with goals to have these discrepancies identified in 2oSee 62 FR 54461. Also see SECY 96-154, " Proposed Revision to NRC Enforcement Policy ,
NUREG-1600, Enforcement Guidance for Departures From the FSAR in Violation of 10 CFR 50.59 and for Failures to Update FSAR in Violation of 10 CFR 50.71(e)," dated July 5,1996.
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the near term . . The two year period will provide a reasonable time period and incentive for licensees to plan and conduct appropriate reviews to ensure that their facilities meet the descriptions in the [ updated] FSAR and take necessary corrective action.
This enforcement discreticn currently ends on October 18,1998. Due to the proximity of October 18,1998, to the date of this generic letter, however, the Commission wiil be revising the enforcement policy to modify the enforcement discretion as follows. The NRC does not intend to continue its exercise of discretion for NRC-identified violations associated with the accuracy of the FSAR beyond October 18,1998. After that time, the NRC expects FSARs to be accurate. Regarding completeness of the updated FSAR, in order to be granted discretion, licensees must use the categorization of SSCs performed as part of a licensee's program to comply with the maintenance rule,10 CFR 50.65, using Regulatory Guide 1.160, Revision 2,
" Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," dated March 1997. For those sections of the FSAR containing information that pertains to structures or systems2i categorized as having high safety significance for purposes of the maintenance rule, licensees must ensure that the updated FSAR is also comotete within six months of the issue date of this generic letter. For other information in the updated FSAR, licensees must have an updated FSAR that is also comolete within 18 months of the issue date of this generic letter.
Backfit Discussion As previously discussed in the " Background" and " Discussion" sections, as a result of lessons leamed from the Millstone experience and other initiatives related to updated FSARs, the NRC determined that additional guidance for complying with $50.71(e) was necessary. As a result of a lack of prior definitive guidance conceming the requirements of the update rule and the absence of detailed staff reviews of the periodic updates, staff positions were not clearly articulated nor did industry unifomily implement the update rule. Although the staff positions in this generic letter are consistent with the requirements of the update rule, for some plants they could be considered to be changes from previous staff positions applicable to those plants, and therefore considered backfits as defined in 10 CFR 50.109(a)(i). Because established regulatory requirements exist but are not being satisfied, these backfits are necessary to bring licensees into compliance with S50.71(e). Therefore, on the basis of 10 CFR 50.109(a)(4)(i), a full backfit analysis was not performed. An evaluation was performed in accordance with NRC procedures, including a statement of the objectives and reasons for the requested actions and the basis for invoking the compliance exception, the results of which follow.
The " Scope" section is derived from a clear reading of the rule, and, in general, is consistent with past staff practice in inspection and enforcement even though a definitive staff position had not been previously explicitly stated. Therefore, the " Scope" section is considered a compliance i
backfit in accordance with 10 CFR 50.109(a)(4)(i).
l 2'lf only one or more components in a system or structure are categorized as being of high safety significance, licensees must treat the entire structure or system to which the component belongs as having high safety significance and ensure that all information in the updated FSAR pertaining to that system or structure is complete.
17 l
The " Level of Detail" section was derived from the Supplementary Information for the update rule, and is generally consisteni with past practice by both industry and the staff. However, some licensees may not have been aware of the level of detail expected to be included in the updated FSAR for safety evaluations periormed pursuant to 50.59 and, therefore, the guidance in the " Level of Detail" section may represent a changed staff position for some licensees. This changed staff position is a compliance backfit pursuant to 10 CFR 50.109(a)(4)(i).
The " Format" section imposes no new staff position, and simply notes that the format of the updated FSAR is at the option of the licensee. Since licensees need take no action in response to the guidance in this section it is not a backfit.
The " Removal of Information Not Associated With a Change" represents a relaxation of the previous staff position that information could not be removed from the updated FSAR in the absence of an explicitly codified process to do so. The request by the staff that licensees provide documentation for information removed from the updated FSAR or relocated to other licensee-controlled documents does represent a new staff position and could be considered a backfit. However, the staff is not imposing this guidance as a requirement, but merely encourages licensees to provide such documentation to ensure that licensee decisions can be understood. Therefore, the guidance in this section is not a backfit.
The staff has not had a uniform position regarding the type of drawings required to be in an updated FSAR. Therefore, the guidance in the " Drawings" section could represent a changed staff position. The guidance in this section was developed to ensure that the updated FSAR would continue to contain information required to be in the updalbd FSAR and, therefore, the guidance in this section represents a compliance backfit pursuant to 10 CFR 50.109(a)(4)(i).
The " Historical Information" section is a type of format change which, as previously noted, is at the option of the licensee. However, the staff believes that some licensees may have removed some historical information that is required to be in an updated FSAR. If this information was removed with the knowledge and tacit approval of the NRC, the guidance in this section could represent a changed position. As the information in tha " Historical Information" section is clearly required to be in an updated FSAR, the guidance in this section for such licensees represents a compliance backfit in accoMance with 10 CFR 50.109(a)(4)(i).
The guidance in the " Frequency of the Periodic Update Submittals" is a restatement of a clear requirement of the update rule. However, the staff may in the past have provided informal guidance that was inconsistent with the requirements of the update rule and therefore, the guidance in this section may represent a changed staff position for some licensees. Since the reporting frequency requirement in 550.71(e)(4) is clear, the guidance in this section represents a compliance backfit pursuant to 10 CFR 50.109(a)(4)(i).
The guidance in the " Temporary Modifications" section represents a new staff position. This staff position is consistent with the requirements of the update rule (and may, in fact, be less inclusive than a literal reading of the rule) and, therefore, the guidance in this section represents a compliance backfit in accordance with 10 CFR 50.109(a)(4)(i).
18
The " Treatment of Nonconforming Conditions Between the Facility and the Updated FSAR" section provides no new guidance but merely refers licensees to Generic Letter 91-18, Revision 1, and thus this section does not represent a backfit.
The " Treatment of FSAR Information Related to Removal of or Retirement-in-Place of SSCs" I
section simply notes that the staff position applies to both operating and decommissioning plants. The staff position is not a new staff position, therefore, this section is not a backfit.
The " Exercise of Enforcement Discretion Regarding Complete and Accurate Updated FSARs" section imposes no requirements and, therefore, is not a backfit.
Although the guidance in this generic letter may, in some cases be compliance backfits in accordance with 10 CFR 50.109(a)(4)(i) and, therefore, not reqwie an evaluation pursuant to 10 CFR 50.109(c)(9), the staff will nevertheless explain here why it has identified the guidance l in this generic letter as " interim." As described in the " Background" discussion, NEl has developed a draft guidance document, NEl 98-03, conceming implementation of the update rule. Although the staff cannot endorse the current NEl 98-03 in all respects without rulemaking, the staff may in the future endorse NEl 98-03 if NEl 98-03 is modified to conform to the guidance in this generic letter, or if rulemaking occurs such that certain provisions in NEl 98-03 can be endorsed, or some combination of the preceding. If rulemaking occurs, the staff believes that it is important to have in place guidance for complying with existing requirements in the interim. If NEl 98-03 is modified to conform to the guidance in this generic letter such that the staff can endorse NEl 98-03, then the regulatory guide that endorses NEl 98-03 will become the long-term guidance, and will be consistent with the interim guidance in this generic letter. If NEl 98-03 is not modified and rulemaking does not occur, then the staff intends to reissue the guidance in this generic letter as long-term guidance in the form of a regulatory guide.
Contacts Questions conceming the information in this generic letter should be directed to one of the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager or Office of Nuclear Materials Safety sod Safeguards (NMSS) project manager.
Jack W. Roe, Acting Director l Division of Reactor Program Management Office of Nuclear Reactor Regulation Technical contacts: 1homas Bergman, NRR Egan Wang, NRR (301) 415-1021 (301) 415-1076 E-mail: tab @nrc. gov E-mail: eyw@nrc. gov Stewart Brown, NMSS (301) 415-1021 E-mail: swb1@nrc. gov 19
I i
l ATTACHMENT 2: DRAFT NEl GUIDANCE ON UPDATED FSARS (NEl 98-03)
O
_ xmm m_, - -
- e NUCifAt INit G Y IN5flTUTE Anthony R. Pietrangelo 82a"n$$E November 14,1997 Mr. Jack W. Roe Acting Director, Division of Reactor Program Management OfBee of Nuclear Reactor Regulation .
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Mr. Roe:
The enclosure provides for NRC staff consideration the prelimi y industry document,
" Draft Industry Updats Guidelines for Final Safety Analysis Reports." As discussed at our public meeting on October 9,1997, we are providing this guidance as input to preparation of staff recommendations to the Commission concerning implementation of 10 CFR 50.71(e), the FSAR update mle.
This draft guidance has been developed with the assistance of an NEI task force and the Regulatory Process Working Group. To ensure the timeliness of this input, we are providing the draft document to the staffin parallel with industrywide distribution for a 30-day period of review and comment. As part of our ongoing interactions on this issue, we will inform you of changes and rennements that may result from this review.
Appropriate FSAR update guidance, endorsed by the NRC,is essential to establishing a stable regulatory process to support ongoing FSAR review activities and ensure consistent future implementation of the FSAR update rule. Ourinteractions with the hTC staff on this issue have been constructive and beneficial. We look forward to continuing this dialogue at the public meeting scheduled for November 24.
As a logical follow-on to these discussions, we also look forward to future interactions on broader issues concerning management and oversight of the current licensing basis.
Ifyou have any questions in advance of our November 24 meeting, please contact me at (202) 739-8081 or Russ Bell at (202) 739-8087.
Sincerely, Anthony R. Pietrangelo ARP/RJB/npg Enclosure 1776 i Sittf f. NW EusTI 400 wa$mfNGTON.DC 20006-3708 PMONE 202,73e 8000 Faz 202 788 4 Die
Draft industrv Undate Guidelines for Final Safety Analysis Rmorts
Purpose:
The purpose of this document is to provide licensees guidance for meeting the Final Safety Analysis Report (FSAR) update requirements of 10 CFR 50.71(e).
l Guidance is also provided for removing or otherwise addressing obsolete and less meaningfulinformation consistent with the intent that updated FSARs focus on information that is useful and relevant to support current and future plant operational and regulatory activities.
, Background FSARs originally served as the principal reference document in support of Part 50 license applications. The FSAR described methods for conforming with applicable NRC regulations and contains the technicalinformation required by 10 CFR 50.34, including description of the facility and its operation, design bases and safety analyses.
In 1980, the NRC issued 10 CFR 50.71(e) to require licensees to periodically update their FSARs to ass.ure that the information provided is the latest material developed.
Today, Updated FSARs (UFSARs) are intended to continue to provide an up-to-date description of each plant and, per the Statements of Consideration for the FSAR update rule, serve as a " reference document for recurring safety analyses performed by licensees, the Commission, and other interested parties." In particular, the UFSAR defines the scope of applicability for the 10 CFR 50.59 change process.
As discussed in SECY-92-314, SECY-97-205 and other Commission papers, both the industry and NRC have long recognized that current UFSARs vary widely in their scope and content. While all UFSARs generally contain a similar core of safety and technical information (e.g., design bases, accident analyses, etc.), later licensees, especially these receiving their operating licenses after 1980, were required to address significantly more topics and do so in significantly greater detail than earlier licensees.
Some plants were licensed with FSARs consisting of just a few volumes. Later FSARs l grew to be 20-3ti volumes and, as acknowledged in draft NUREG-1606, "might have more detailin certain respects than was absolutely necessary for the staff's review."
UFSARs have generally not grown much beyond the size of the original FSAR. This is consistent with the FSAR update rule which did not require that updates be of greater detail than the original FSAR.
Recent inspections by the NRC and licensees have identified numerous discrepancies l between UFSAR descriptions and the actual plant configuration and operation. These DRAFT- 11/14/97 1
i findings have raised questions about possible noncompliance with 10 CFR 50.71(e).
The industry has developed this guidance in recognition of the importance of the UFSAR, the need to comply with 10 CFR 50.71(e) update requirements, and the need
' for UFSARs to be consistent with the plant configuration and operation. This guidance is intended to assist licensees in conducting ongoing FSAR reviews and provide a basis for consistent future implementation of the FSAR, update rule.
Implementation in conducting ongoing FSAR reviews, the first priority of licensees should be on assuring the accuracy of design bases and other safety significant information. It is expected that NRC inspection and enforcement of UFSAR compliance will be similarly focused on safety significant information.
Scope of UFSAR Updates This section provides guidance on the scope of required UFSAR updates. Table 1 identifies the six substantive update requirements of 10 CFR 50.71(e) and provides corresponding guidance for meeting each requirement. The full text of 10 CFR 50.71(e)is provided in Appendix A. Examples illustrating the guidance are provided in Appendices B-F.
Appendix B - examples of UFSAR updates to reflect new or amended regulations Appendix C - examples of UFSAR updates to reflect license amendments or changes under 9 50.59 Appendix D -examples of license amendments or changes under 9 50.59 did agt result in an of update to the UFSAR Appendix E - examples where new generic or plant specific issues resulted in a change to the UFSAR Appendix F - examples where new generic or plant specific issues did ng1 result in a change to the UFSAR DRAFT- 11/14/97 2
Table 1 10 CFR 50.71(e)
Requirement Guidance
- 1. Licensees shall periodically . Through the update process, UFSAR information update FSARs 'to assure that should be maintained accurate and up to date, the information included in the including changes, addition-s or deletions to the FSAR contains the latest descriptions, design bases and safety analyses material developed." relied upon by the NRC for initial licensing. Both general and specific descriptions should be consistent with the current plant configuration and operation.
Per 10 CFR 71(e)(4), updates are to bring the UFSAR up to date as of a maximum of six months prior to submittal.
Requirement Guidance
- 2. FSAR updates "shall contain UFSARs should be updated to reflect plant changes all the changes necessary to resulting from new or amended regulations, e.g.,
reflect information and Appendix R, Station Blackout and ATWS, or plant-analyses submitted to the specific orders. In response to such new Commission by the licensee or requirements, it may be appropriate to add certain new prepared by the licensee information to UFSARs consistent with the purpose of pursuant to Commission the UFSAR to provide a reference document for use in requirement since the last recurring safety analyses. The following types of updated FSAR." information may be of potential significance in evaluating future changes under @ 50.59 and should be considered for incorporation in the UFSAR:
e new design bases as defined in 6 50.2 e
description of safety function (s) e summary of relevant safety analyses, includir.g specific operational actions credited Note that certa.in new regulations of a programmatic nature, e.g., the Maintenance and Fitness inr Duty Rules, do not result in information that is significant to
@ 50.59 evaluations. Accordingly,it is not necessary to address licensee actions responding to regulations of this type in UFSARs.
See Appendix B for examples.
DRAFT 11/14/97 3
i
~ .
Table 1 (continued)
,1,9 CFR 50.71(e)
Requirement Guidance
- 3. The updated FSAR shall be e if UFSAR information is affected by a change to the revised to include the effects plant orits procedures, the UFSAR should be of all changes made in the changed to reflect the change to the plant or facility or procedures as procedures.
described in the FSAR.
j . If the UFSAR is unaffected by a change, e.g.,
because the change involved a level of detail beyond the existing UFSAR level of detail for affected equipment or procedures described, no change to the UFSAR is required See Appendices C&D for examples.
i 10 CFR 50.71(e) 3 Requirement Guidance
revised to include the effects evaluations performed in support of license j of- all safety evaluations amendments or 9 50.59 changes, e.g., due to use of performed by the licensee new assumptions or analyses, the UFSAR should either in support of requested be updated to reflect the effects of the safety license amendments or in evaluation.
support of conclusions that changes did not involve an e lf the UFSAR is unaffected by a safety evaluation, unreviewed safety question, e.g., for a change to a procedure not described in i the UFSAR, no change to the UFSAR is required.
See Appendices C & D for examples.
l DRAFT- 11/14/97 4
Table 1 (continued) 10 CFR 50.71(e)
Requirement Guidance
- 5. The updated FSAR shall be e if licensee analysis or action in response to a new revised to include the effects plant-specific or generic issue affects information of all analyses of new safety contained in the UFSAR, the UFSAR should be issues performed by or on updated to address the issue and reflect the result of behalf of the licensee at the analysis or action.
Commission request.
- To the extent UFSARs are supplemented to reflect actions taken in re.3ponse to a new issue, the new information added to the UFSAR should be consistent with the purpose of the UFSAR to provide a reference document for use in recurring safety analyses. The following types of information may be of potential significance in evaluating future changes under 9 50.59 and should be considered for i
incorporation in the UFSAR:
e new design bases as defined in f 50.2 e description of safety function (s)
- e summary of relevant safety analyses, including specific operational actions credited e
if a new issue does not require action by a particular l licensee or if the licensee analysis or action does not i affect information described in the UFSAR, then no change to the UFSAR is required.
See Appendices E & F for examples.
l
' 10 CFR 50.71(e) Guidance Requirement l 6. The updated information shall . Whenever possible, UFSAR changes should be be appropriately located incorporated in the existing text, tables or figures to '
within the FSAR. maximize clarity and ensure that all the needed corrections are made if the subject of the evaluation or analysis has not been previously addressed in the l UFSAR, the new information may be appropriately located in a new section or an appendix of the UFSAR.
- Information that is appropriate to include in the UFSAR l and is part of a separate controlling document may be i
incorporated in the UFSAR by appropriate reference to that information. Later updates should reference the current revision of the controlling document.
DRAFT- 11/14/97 5 l
l
Level of Detail for UFSAR Updates The Statements of Consideration for the FSAR update rule state, "the level of detail to be maintained in the FSAR should be at least the same as originally provided." The practicalinterpretation of this has been that the level of detail of the original FSAR dictates the appropriate level of detail for updates. In determining the level of detail for UFSAR updates, licensees may refer to the revision of Regulatory Guide 1.70 or predecessor guidance appropriate for their plant and similarly to NUREG-0800, the Standard Review Plan.
Updated UFSAR information should reflect a level of detail consistent with that which it replaces or modifies. If a change is to an SSC, program or procedure not mentioned in the UFSAR or involves a level of detail beyond that currently described in the UFSAR, then no update to the UFSAR is necessary to reflect the change.
Where new information is being added to the UFSAR, e.g., to include new $ 50.2 design bases or safety functions, licensees should provide a level of detail consistent with related or similar information existing in the UFSAR. Licensees may provide additional detail as appropriate based on the technical complexity of the information, the amount of information of potential significance to future f 50.59 safety evaluations, or to address a specific regulatory concern.
Format of UFSAR Updates NRC regulations do not address the format of the FSAR or the updates required by 10 CFR 50.71(e). However, consistent with the Statements of Consideration for the FSAR update rule, the format for UFSAR updates is expected to be consistent with that of the original FSAR. Licensees may adopt the format of Regulatory Guide 1.70 at their own discretion.
Temporary Changes The UFSAR is intended to be consistent with the current plant configuration and operation. This notwithstanding, at any given time there may be a number of temporary plant and/or procedura changes in effect to support corrective action, maintenance or other plant activity. Temporary changes in support of plant operations are intended to 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, Appendix B. Per Generic Letter 91-18, Revision 1, temporary conditions subject to Appendix B that exist longer that the next refueling outage are to be explicitly justified as part of tracking documentation.
Temporary changes should not be reflected in UFSAR updates. Because UFSAR information lags the current plant status by 18-24 months, the UFSAR is a inefficient DRAFT- 11/1497 6
= .
l vehicle for documenting conditions of a temporary nature. Moreover, temporary changes, by their nature, do not after the design bases of the plant. Temporary changes are administratively controlled separately from the UFSAR, and the current status of each is tracked to completion. Tracking documentation ensures that plant staff can determine the {
current plant status to support ongoing plant operations, including safety evaluations performed under 10 CFR 50.59. For temporary changes subject to 10 CFR 50.59, safety evaluations are performed and submitted to the NRC in accordance with 50.59(b). For the reasons discussed above, it is unnecessary and inappropriate for UFSARs to duplicate l the licensee's tracking and reporting of temporary changes. '
If corrective action or other work associated with a temporary modification results in a l permanent change to the plant as described in the UFSAR, then the UFSAR should be l updated to reflect the change.
1 Obsolete and Less Meaningful UFSAR Information '
In the SRM responding to SECY-97-036 (Millstone Lessons Leamed Part 2), the l Commission stated that implementation of 10 CFR 50.71(e) should " allow obsolete and ,
less meaningfulinformation and commitments to be readily removed from the FSAR." '
l t
Removing such material willimprove the focus of UFSARs on significant descriptive, design bases, and analyticalinformation that is useful and relevant to support current and future plant op.erational and regulatory activities.
Discussed below are three categories of obsolete and less meaningfulinformation:
- 1. Obsolete and redundant information
- 2. Historical material
- 3. Other less meaningful UFSAR information Removal of UFSAR material must be administratively controlled. Deleted material and the basis for its deletion from the UFSAR must be retained by licensees. Appendix G provides examp!es of information that may be appropriately deleted from the UFSARs.
- 1. Obsolete and Redundant Information Deletion of obsolete or redundant information is consistent with the purpose of the UFSAR to provide a reference document for use in recurring safety analyses (e.g., g 50.59 safety evaluations) and the intent that UFSARs focus on information that has continuing safety or regulatory significance.
The following types of obsolete or redundant information may be deleted from UFSARs:
DRAFT - 11/14/97 7
Inforrnation relevant to SSCs, programs, procedures or organizations that are no longer in use or no longer exist (e.g., Construction Quality Assurance Program).
Information that is redundant to that found elsewhere in the UFSAR.
Note: When deleting duplicate information from one or more locations, it may be appropriate to provide a reference to the UFSAR section where the information is retained.
Information that is duplicative to that contained in a controlling program document or technical report such as the Emergency Plan, Offsite Dose Calculation Manual, Security Plan, Quality Assurance Plan, and Environmental Protection Plan.
Note: it may be appropriate to replace the deleted material with a brief summary of key information and/or specific reference to the information in the controlling document. Information referenced by UFSAR is considered part of the UFSAR.
- 2. Historical Material Historical information is information that was accurate and relevant at the time the plant was originally licensed, but which is no longer useful or relevant to current and future operational or regulatory activities. This includes information concerning initial plant licensing and start-up, as well as information on natural and certain man-made phenomena outside the control of the licensee. Such historicalinformation is not intended or expected to be updated for the life of the plant;is not affected by changes to the plant or its operation, and even if updated, would not affect the plant design bases. Accordingly,it is appropriate to remove historicalInformation from the UFSAR, thus excluding it from the material that is actively maintained by licensees per 10 CFR 50.71(e), is within the scope of 10 CFR 50.59, and is subject to NRC inspection.
The following are examples of information appropriate for historical designation:
- Pre-service inspections
- Preoperational tests
. Start-up tests e
Comparative plant data provided to support original plant licensing Lists of references, figures and submittals relevant only to the original licensing proceeding Description of original factory testing of plant equipment, e.g., emergency diesel generators Site characteristics (typically in UFSAR Chapter 2) such as geography, meteorology, hydrology, geology, and seismology (all natural phenomena of primary relevance to original plant siting) -
DRAFT- 11/14/97 8
r------------------------------
Licensees may remove historicalinformation as described above by one of the following, or equivalent, methods:
Historicalinformation may be " retired in place" within the UFSAR by designating it
. via clear annotation as historical material, retained for information only.
Historicalinformation may be relocated to a specially designated appendix of the UFSAR or other centrallocation.
Historicalinformation may be removed from the UFSAR, and the original FSAR ma be relied upon for historical reference.
- 3. Other Less Meaninoful UFSAR Information i
The principal continuing purposes of the UFSAR are to provide an accurate, up-to-date l
description the plant and its operation and to provide a reference document for recurring safety analyses, including 10 CFR 50.59 safety evaluations. Detailed '
information that is of negligible value relative to these purposes is appropriate to remove from UFSARs. Removal of excessively detailed information willimprove the focus of UFSARs on significant descriptive, design bases, and analyticalinformation that is relevant and useful to support current and future plant operational and regulatory activities.
i The following types of excessively detailed information are appropriate to delete from UFSARs, except as indicated by applicable regulatory guidance or NRC Safety Evaluation Reports:
Descriptive information that is not important to the UFSAR user's understanding of the plant's configuration and operation from either a general or more specific
, functional perspective.
Detailed design information that is not important to the description of the facility, or presentation of its safety analysis and design bases as defined in 9 50.2, e.g.,
component d,etails such as specific motor horsepower ratings that merely implement the stated design basis (such as " sufficient horsepower to open an MOV under differential pressure conditions" determined using a specified methodology).
Detailed 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 bases function (s).
Drawing details beyond those necessary to support the textual discussion, e.g.,
instruments not described in UFSAR text, pipe line numbers, vents and drains, etc.
(in most cases, P&lDs may be replaced with simplified sketches that complement the text.) '
DRAFT- 11/14/97 9
l
.-.-----.-.-.w------..-;.------------
. Detailed analytical information, e.g., detailed calculations, that is not important to the UFSAR user's understanding of the safety analysis methodology, inputs assumptions, and results, and/or compliance with relevant regulatory and industry standards.
Removal of excessive detail from UFSARs does not diminish the effective scope of implementation of the 10 CFR 50.59 change process. The industry's historically broad interpretation of the rule language and industrywide implementation of NEl 96-07,
" Guidelines for 10 CFR 50.59 Safety Evaluations," ensures that proposed changes will continue to be thoroughly evaluated and unreviewed safety questions will continue to be consistently and conservatively identified.
DRAFT- 11/14/97 10
Anoendix A 10 CFR 50.71(e) l 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 meterial developed. This submrttal 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 of: all changes made in the facility or procedures as described in the FSAR; all safety evaluations performed by the licensee either in support of requested license amendments or in support of conclusions that changes did not involve an unreviewed safety question; 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 FSAR.
(1) The licensee shall submit revisions containing updated information to the I Commission, as specified in (section] 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 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 Office 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.
DRAFT- 11/13/97 A1
1 (4) Subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 rnonths. The revisions must reflect all changes up to a maximum of 6 rnonths prior to the date of filling.
For nuclear power reactor facilities that have submitted the certifications required by s50.82(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 identification (date of change or change number or both).
(6) The updated FSAR shall be retained by the licensee until the Commission j terminates their license.
DRAFT- 11/13/97 A2
Appendix B Examples of UFSAR updates to reflect new or amended regulations:
- 63) and regulatory guidance (RG 1.155). In 1988, the NRC amended its regulations to include the requirement that each light-water cooled nuclear power plant be able to withstand and recover from a Station Blackout (SBO) of a specific duration without sustaining reactor damage. In addition, the NRC issued RG 1.155 which describes means acceptable to the NRC staff for meeting the requirements in 10 CFR 50.63. An alternate AC (AAC) diesel generator was installed to provide emergency power in the event of SBO, and the UFSAR was later updated as follows: A new section (9.5.11) was added describing the AAC diesel generator.
Existing sections and figures were modified to describe its supporting systems and identify mechanica: and electrical connections to the station. Chapter 1 was revised to reflect the SBO building in the general description of the plant.
- 2. 10 CFR 50.62 (the ATWS rule) required a new mitigation system be installed that was specific to the type of plant (Westinghouse, Combustion Engineering, etc.).
The licensee added new information to the UFSAR based on the evaluation provided by the plant designer. The information was added to the UFSAR section on design basis accidents in a level of detail similar to that of other accident analyses.
- 3. As a result of adopting the new 10 CFR Part 20, numerous changes to the UFSAR were required to create / modify the definitions of terms such as restricted area, controlled area, effluent concentration, derived air concentration, high radiation area, and very high radiation area.
- 4. The NRC approved a license amendment to follow the performance-based option for containment leakage testing (10 CFR 50, Appendix J, Option B). The UFSAR was revised to replace discussions about the previous test frequency with references to Option B of the revised Appendix J.
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... 1 Appendix C Examples of UFSAR updates to reflect license amendments or changes under 10 CFR 50.59:
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- 1. The containment humidity monitoring instrumentation was abandoned in place as part of a design change performed under 10 CFR 50.59. The 3
UFSAR was revised to reflect the plant modification.
L 2. A proposed technical specifications change taking credit for the Alternate AC diesel generator was sent to the NRC in 1995. That TS change, when approved by the NRC, will result in a change to the UFSAR regarding the use 1 of the AAC diesel generator to reduce the risk associated with performing preventative maintenance on the emergency diesel generators during any mode of operation.
- 3. A plant procedure was revised under 10 CFR 50.59 to allow use of an l alternate reactor coolant system vacuum venting system and process instead of normal fill and vent process previously described in the UFSAR. The procedure change also provides an alternate method of drawing a steam bubble in the pressurizer rather than as described in the UFSAR. The UFSAR update included descriptions of system operation to prevent air l inteakage, vent path, location of vacuum connection including approximate vacuum established, and general steps in raising RCS level concluding with establishment of steam bubble. This information was an equivalent level of detail to that previously contained in the UFSAR.
- 4. A licensee received a license amendment that deleted chlorine j instrumentation from the Technical Specifications because chlorine gas
) intrusion was no longer a credible event. The UFSAR was subsequently changed to delete references to chlorine gas intrusion.
- 5. The use of ZlRLO clad fuel was approved for a licensee through a license amendment. The description of fuel assemblies in the UFSAR was changed l
to reflect that the fuel rods could be clad with Zircaloy or ZlRLO to cover any possible combination of the old and new fuel cladding that could be present in the core during subsequent reloads.
- 6. Reanalysis and safety evaluation under 10 CFR 50.59 was conducted to only credit "one train" of ESF equipment to achieve safe shutdown after a fire in lieu of previous licensing basis crediting "two" trains of the licensee's three train design. The effect of safety evaluation required updating of the combustible loading table in UFSAR. -
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Appendix D Examples of license amendments or changes under 10 CFR 50.59 that did B2t result in an of update to the UFSAR:
- 1. A licensee proposed a technical specification change involving surveillance requirements and allowed outage times for the emergency diesel generators. Because the licensee's UFSAR only describes EDG i
' surveillance testing as being in accordance with the manufacturer's recommendations, the TS change involved a level of detail beyond that discussed in the UFSAR. Since no explicit time requirements were discussed, no change to the UFSAR was made.
- 2. A licensee had a new license condition requiring corrosion testing for laser-welded sleeves in the steam generators. The UFSAR does not provide details on the steam generator plugs or sleeves;it states only that the steam generators may be repaired. Since there is no mention of the types of repair devices, installation, or inspections, it was not appropriate to add this detail about one type of test to the UFSAR. Additionally, Applicable regulatory guidance did not indicate that such a detail should be included.
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- 3. The surveillance interval for selected slave relays was extended from quarterly to every 18 months through a license amendment. The UFSAR was not changed because the surveillance interval for the slave relays is not specifically listed in the UFSAR. Also, the change in the surveillance interval did not alter compliance with the testing requirements specified in the IEEE standards to which the licensee is committed in the UFSAR.
- 4. The procedure that describes diagnostic testing of rising stem motor-operated valves (MOV) was revised under 10 CFR 50.59 to require recording of specific work activities on a checklist. Specifically, recording was required 1 ) if the springpack was removed and the MOV database was updated to reflect if the springpack was modified,2)if adjustments were
! made that affected actuator operation, and 3) that the Local Leak Rate l Testing Coordinator was contacted if the MOV's closing characteristics I changed as a result of work activities. The UFSAR was not changed because this level of detail does not currently exist in the UFSAR. Also, NUREG-0800 does not specify that such detailed work activities should be described.
- 5. Non safety-related cooling water pump impellers were changed under 10 CFR 50.59 from carbon steel to stainless steel. The pumps are mentioned in the UFSAR, however, because the impeller material is beyond the level of detail discussed in the UFSAR, the UFSAR was not changed.
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Appendix E Examples where new generic or plant s,pecific issues resulted in a change to the UFSAR:
- 1. The UFSAR was revised to add more detail on the heavy loads program including the commitments to section 5.1.1 of NUREG-0612. This change to the UFSAR was in advance of the issuance of NRC Bulletin 96-02. NRCB 96-02 requested licensees to conduct a review of plans and capabilities for handling heavy loads.
As a result of NRCB 96-02, additional changes to the UFSAR are planned to improve the description of heavy loads and their handling.
- 2. Because licensee actions related to NRC Bulletin 92-01 (Thermolag issue) affected the Fire Protection Report (Part of the UFSAR by reference), the Fire Protection Report was modified and the UFSAR was changed to reflect the updated reference.
- 3. NRC Generic Letter 89-009,"ASME Section 111 Component Replacements,"
provided guidance for replacing components that were constructed to Section ll1 of l l the ASME Boiler and Pressure Vessel Code but which are not currently available in I i
full compliance yvith the stamping and documentation requirements of tl)e code. If l licensees choose to use the staff position, they need only indicate such replacements in the UFSAR update and certify their compliance with the guidance of the generic letter. As a result, the UFSAR was updated to add a section to l
i Chapter 3 of the UFSAR that included a brief paragraph regarding the use of NRC '
Generic Letter 89-009 for ASME component replacements and a Table with a listing of replacementitems.
- 4. For a particular plant, the ultimate heat sink for a design basis seismic event is connected to the safety-related pump bay through a 36" pipe. A non-routine test of this pipe determined that the pipe could not pass the design flow credited in the UFSAR. It was determined that the water in the nonsafety-related intake canal must be relied upon in order to provide adequate time for operator action to manage the cooling water system.
This represented a change in the plant design bases as defined in 10 CFR 50.2 and discussed in NEl 97-04, Design Basis Program Guidelines. Thus a change was made to the UFSAR to reflect reliance on the nonsafety-related intake canal to support the ultimate heat sink function.
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- 5. NRC Bulletin 88-04, " Potential Safety-Related Pump Loss," requested the evaluation of all safety-related pumps for 1) pump-to-pump interaction during miniflow operation that could result in the dead-heading of one or more of the damage resu)lting from operation and testing in the minim evaluation of the safety injection pump minifiow lines was performed by the safe injection pump supplier in response to NRC Bulletin 88-04. Because this evaluation included hydraulic instability at low flow conditions, not previously addressed, the safety injection pump supplier increased his recommended miniflow rates. In response to the results of this evaluation, the orifices in the safety injection recirculation lines were modified to provide an increased miniflow rate that provided the proper balance between the required safety injection flow rate and the time the pump is expected to be on miniflow. The Bulletin 88-04 concern and the resulting plant change were reflected in the UFSAR.
- 6. Generic Letter 88-17, " Loss of Decay Heat Removal" requested the identification of Technical Specifications that restrict or limit the safety benefit of actions identified in
- GL 88-17 and that appropriate TS changes be submitted. The NRC and the ind had recognized the safety benefit in removing the autoclosure interlock circuitry from the Reactor Heat Removal system. The NRC approved TS amendments removing the automatic isolation requirement for the RHR suction valves.
Concurrently, a facility change removed the autoclosure feature and the disadvantage of the possibility of an inadvertent valve closure during RHR operation resulting in the loss of decay heat removalcapability. The UFSAR was changed to remove the description of the automatic isolation requirements for the
, RHR suction valves.
I 7. A licensee has two safety trains of emergency feedwater which are totally independent except for a specific small break LOCA accident condition with a i
narrow spectrum of break sizes. In order to be able to meet the existing design basis, the licensee has taken an existing valve in the crosstie lines between the two systems, added a motor operator to it, and added a safety function to the valve to open and crosstie the trains. In a future UFSAR update, the licensee will describe this new safety function.
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Appendix F l
Examples where new generic or plant-specific issues did agi result in a change to the UFSAR:
- 1. The Flow Accelerated Corrosion (FAC) program is an example of a program that was developed in response to a NRC issue but is not discussed in the UFSAR. NRC Bulletin 87-01, Thinning of Pipe Walls in Nuclear Power Plants," requested information concerning programs for monitoring the thickness of pipe walls in high energy single phase and two phase carbon steel piping systems. NRC Generic Letter 89-09, " Erosion / Corrosion Induced Pipe Wall Thinning," requested assurance that a systematic erosion / corrosion program was implemented for single phase and double phase high energy carbon steel lines. The licensee implemented a piping 1
- inspection program which consists of a systemic and formalized l erosion / corrosion monitoring program for carbon steel, high energy, l secondary piping components. The piping inspection program was developed to provide a standardized method of identifying, inspecting, evaluating, and tracking piping components that are potentially susceptible to erosion / corrosion (single or two phase). This inspection program is implemented procedurally. The UFSAR was not updated to reflect the new piping inspection program.
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- 2. Generic Letter 89-10 provided information on motor-operated valve issues. The licensee developed a new testing program in response to the GL. The program was not described in the UFSAR because the previous MOV testing requirements had not been included. In addition, the applicable regulatory guidance did not indicate that this information should be discussed in UFSARs.
- 3. NRC Generic Letter 95-07," Pressure Locking and Thermal Binding of Safety -
Related Power Operated Gate Valves," requested licensees to evaluate valves potentially susceptible to pressure locking or thermal binding and perform analysis i or corrective action as necessary to ensure these valves would perform their i
intended safety functions. This licensee responded by stating the evaluation and analysis were performed using a formal engineering calculation criteria and provided a summary of the conclusions. The generic issue and the results of the evaluation and analysis were not included in a UFSAR update because this level of detail was not previously described in the UFSAR. This licensee typically .
documents this type of generic issue in engineering documents, reports their l completion and considers the results subject to NRC inspection. If the results of the '
analysis do not impact any analysis conclusions in the UFSAR, the analysis results l are not added to the UFSAR. I DRAFT- 11/18/97 F-1
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Appendix G Examples of information deleted from the UFSAR and the rationale for the deletion.
- 1. A UFSAR table that describes emergency diesel generator loading requirements includes detailed description of the individualloads on each motor control center that would or could be placed on the bus following a LOCA with a loss of offsite power. This information was taken directly from a design analysis and is too detailed with respect to the purpose of the UFSAR discussion, which is to
[ demonstrate that the EDGs are capable of performing their safety function. The l detailed information on individual EDG loads may be deleted the from the UFSAR.
- 2. A licensee initiated changes to tho UFSAR for the second ten-year ISI and IST program plans by making the detailless specific. The UFSAR includes a statement of compliance with the code. The licensee determined that it was not necessary to duplicate the information that was provided in the program plan, which was submitted as part of a Code requirement. This utility notes that the removal from the UFSAR of detailed ISI and IST program information is consistent with the practice whereby many other programs, and therefore, changes to those programs, have never been included in the UFSAR. Also, many programs are not addressed in applicable regulatory guidance.
- 3. A licensee deleted sections describing an accident that occurs when transitioning from three-loop operation to four loop operation. The Technical Specifications do not allow three-loop operation. The details of the accident I were out of date, and, rather than updating the analysis, it was more reasonable to delete the non credible accident entirely.
- 4. A licensee is preparing a change package to delete the large list of figures in FSAR Section 1.7 provided to the NRC as part of the originallicensing. It is being replaced with a list of current drawings and UFSAR figures. The deleted list is still available in the original FSAR, and a reference to it will also be included in the UFSAR.
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- 5. A licensee deleted a large portion of Section 13.1, Organizational Structure, and 13.3, Emergency Planning, and replaced them with less detailed descriptions and references to the QA Topical Report and Offsite Dose !
Calculation Manual, respectively. These referenced documents provide the !
most current information, are generally updated more frequently, and are the l controlling documents already submitted to the NRC under different - '
regulations.
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- 6. After determining that deletions were not inconsistent with applicable i regulatory guidance, a licensee deleted occasional words or sentences that are irrelevant to the subject of a paragraph, or are duplicated in another section.
- 7. A licensee is developing a package to delete several paragraphs that address a completed turbine refurbishment program. Completing the program did not affect the design or function of the turbines described in the UFSAR. The historical information is not relevant to current operation, and its deletion is not l inconsistent with applicable regulatory guidance.
l 8. A licensee deleted information under chemical volume and control system l regarding reactivity control. The deleted information discussed actions taken in the event of an inoperable boration flowpath. The rationale was that these actions are already described in the Technical Requirements Manual.
l 9. A licensee deleted information in Chapter 10 of the UFSAR regarding heat balance diagrams. The information was determined to be in excess of that l needed to ensure the understanding of the reader or on the basis of the NRC SER, the Standard Review Plan, applicable regulatory guidance, and ;
licensing commitments. t 10.The Nuclear Safety Operational Analysis was performed to support the originally submitted technical specifications and was included as an appendix to a UFSAR. The appendix was extensively revised in connection with bringing the plant's technical specifications into alignment with those of other plants of similar vintage. The majority of the current discussion in the l
appendix concerns how the analysis was performed and is of negligible value '
to the NRC or plant staff. Therefore it may be deleted from the UFSAR.
- 11. A licensee replaced the following UFSAR information with reference to the controlling program document:
- list of instruments required to be operable for fire detection and suppression !
- atmospheric dispersion factors tables e summary descriptions of Inservice inspection requirements 4
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