NRC Generic Letter 1981-06

NRC Generic Letter 1981-006: Periodic Updating of Final Safety Analysis Reports (Fsars)

ML031080517
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Calvert Cliffs, Dresden, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Catawba, Harris, Wolf Creek, Saint Lucie, Watts Bar, Hope Creek, Grand Gulf, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Columbia, Seabrook, Brunswick, Limerick, Turkey Point, River Bend, Crystal River, Haddam Neck, Diablo Canyon, Callaway, Vogtle, Waterford, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Quad Cities, La Crosse, Big Rock Point, Zion, Midland, Bellefonte, LaSalle, 05000363, 05000355, Zimmer, Washington Public Power Supply System, Shoreham, Satsop, Bailly, Atlantic Nuclear Power Plant, Cherokee, Marble Hill, Hartsville, Phipps Bend, Yellow Creek
Issue date:	02/26/1981
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:
References
GL-81-006, NUDOCS 8103230813
Download: ML031080517 (13)

I

FF3, ".' 31 PLANTS UNDEIR or. REVIEW

(/evA, 0e Aftkr

1. Clinton 1/2

2. Byron 1/2

50-461/462

50-454, 455 r176

3. Braidwood 1/2 50-456/457

4. LaSalle 1/2 50-373, 374

5. Midland 1/2 50-329,330

6. McGuire 2 50- 370

7. So. Texas 1/2 50-498, 499

8. Shoreham 50-32 2

9. Waterford 50-382

10. Grand Gulf 1/2 50-416/417

11. Diablo Canyon 1/2 50-275, 323

12. Susquehana 1/2 ,50-387, 388

13. St. Lucie 2 50-389

14. Summer 1 50- 39 5

15. San Onofre 2/3 50-361, 362

16. Bellefonte 1/2 50-438, 439

17. Watts Bar 1/2 50-390, 391

18. Sequoyah 2 50- 328

19. Comanche Peak 1/2 50-445, 446

20.

21. WPPSS-2 50- 39 7

22. Fermi 2 50-341

23. Zimmer I 50 --3:. 8

24 . Perry 1/2 50-440, 441

25. -Palo Verde 50-528, 529, 530

26. Catawba 50-413, 414

27. Marble Hill 50-546, 547

28. Wolf Creek 50-4 82

29. Callaway 50-483, 486

1 IR1O323O81

fEH'i -* 19YWI

PLANTS UNDER (CONSTRUCTION

1. Cherokee 1/2/3 50-491, 492, 493

2. Beaver Valley 2 50-412

3. St. Lucie 2 50-3 89

4. Vogtle 1/2 50-424, 425

5. River Bend 1/2 50-458, 459

6. e

7. Forked River 50-36 3

8. Nine Mile Point 2 50-410

9. Millstone 3. 50-4 23

10. BailJy 2 50-367

11 . Limerick 1/2 50-352, 353

12. -Hope Creek 1/2 355

• 50-354,

13. Seabrook 1/2 50-443, 444

14.

15. Hartsville 1/2/3/4 50-518, 519, 520, 521

16. Phipps Bend 1/2 50-553, 554

17. Yellow Crcek 1/2 50-566, 567

18. WPPSS 1/3/4/5 50-460, 508, 513, 509

19 . Harris 1/2/3/4 50-400, 401, 402, 403

20. FNP 50-437

ALL POWER REACTOR LICENSEES

Docket No. 50-348 Docket No. 50-3 Farley Unit 1 Indian Point Unit 1 Docket No. 50-313 Docket No. 50-247 Arkansas Unit 1 Indian Point Unit 2 Docket No. 50-368 Docket 50-286 Arkansas Unit 2 Indian Point Unit 3 Docket No. 50-317 Docket No. 50-155 Calvert Cliffs Unit 1 Big Rock Point Docket No. 50-318 Docket No. 50-255 Calvert Cliffs Unit 2 Palisades Docket No. 50-293 Docket No. 50-409 Pilgrim Unit 1 Lacrosse Docket No. 50-325 Docket No. 50-269 Brunswick Unit 1 Oconee Unit 1 Docket No. 50-324 Docket No. 50-270

Brunswick Unit 2 Oconee Unit 2 Docket No. 50-261 Docket No. 50-287 H. B. Robinson Unit 2 Oconee Unit 3 Docket No. 50-10 Docket No. 50-334 Dresden Unit 1 Beaver Valley Unit 1 Docket No. 50-237 Docket No. 50-302 Dresden Unit 2 Crystal River 3 Docket No. 50-249 Docket No. 50-335 Dresden Unit 3 St. Lucie Unit 1 Docket No. 50-254 Docket No. 50-250

Quad-Cities Unit 1 Turkey Point Unit 3 Docket No. 50-265 Docket No. 50-251 Quad-Cities Unit 2 Turkey Point Unit 4 Docket No. 50-295 Docket No. 50-321 Zion Unit 1 Edwin I. Hatch Unit 1 Docket No. 50-304 Docket No. 50-366 Zion Unit 2 Edwin I. Hatch Unit 2 Docket No. 50-213 Docket No. 50-315 Connecticut Yankee (Haddam Neck) D. C. Cook Unit 1

UNITED STATES

NUCLEAR REGULATORY COMMISSION

g aWASHINGTON, D. C. 205 February 26, 1981 ALL CONSTRUCTION PERMIT HOLDERS AND APPLICANTS FOR OPERATINQ MICEN$ES

Gentlemen:

RE: PERIODIC UPDATING OF FINAL SAFETY ANALYSIS REPORTS (FSARs)

(GENERIC LETTER 81-06)

The Commission approved the rule 50.71(e) (copy enclosed) entitled,

"Periodic Updating of FinWl Safety Analysis Reports" and published the rule in the Federal Register on May 9, 1980. The rule became effective on July 22, 1980.

Although this new rule applies to holders of operating licenses for power reactors, we believe your organization should be aware of it, since, within

24 months after issuance of an operating license or July 22, 1982, whichever is later, the original FSAR submitted as a part of the OL application must be updated in the specific manner provided in the rule. Thereafter, it must be updated at least annually. Each update must reflect all changes up to six months prior to the filing of the update.

Although the rule itself is self-explanatory, several questions have been asked regarding the FSAR's legal status, format and content, and we have provided the enclosed guidance.

Further questions should be directed to the Project Manager for your facility.

\ ncerely, Darrell G irector Division of Licensing Enclosure:

As stated

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Reirlster I Vol. 45. No. 92 1 Friday. May L 1980 1 Rules ia

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Regulations WMENNOMAIN

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• 1UPftKMINTARY INFORMATIOW. On which theNRCstaff is making a November A197L the Nuclear systematic safety evaluation of eleven Regulatory Commission published in the (11) nuclear power facilities licensed for Federal Rjgster (41 FR 49123) notice operation before 172. The purpose of of proposed Ma making invitig vlnttow this systmatleevaluation program suggestions or comments on the ISEP) Is to determine and document the proposed sle by December S&19t A degree to which the eleven (p1)facilitlms notce f correction and extension of mec t licensing requirements for comment period was published In the new plants. Of the tva (5) plants Federal Register on December 27, 19 li sd por o January 1 1983 that are

141 FRS O In whIch the comment si lI sed to operate, three (3)are period was extended to January 28.1977. Included In the SEP. Th remaining two the notices concerned proposed (23 plants.' which presently are shut atendments to 10 CFR Part 50 down, will be subject to the provisions Licening of Production and Utilization of the nrle as long as their licenses Facilities." to require each applicant for. authorize operation or holder of, a power reactor operating The licensees participating in the SEP

license which would be or was issued probably will be requested to supply a after January 1,1963 to submit considerable amount of Information periodically to the Commission revised during the program. Requiring them In pages for its Final Safety Analysis addition. to update their FSARs could Report (FSAR). These revised pages prove to be excessively burdensome and would Indicate changes made In the cauld result In duplication of reports.

facility or the procedures for its The Information generated during the operation and any analyses affected by program and the manner in which it i NUCLEAR REGULATORY these changes. Thirty-one persons collated wM result in a completed FSAR

COMMISSION submitted comments regarding the at the concluson of the program For proposed amendments. The commenters these reasons licensees of facilities

10 CFR Part 60 could be roughly divided Into three groups with seventeen supporting the being subjected by the NRC to a Perlodlc Updating of Final Safety systematic evaluation program will not nile with comments, eleven opposed to be required to comply with the Anlysis Reports the rue. and three neutral. Copies of the provisions of thfs rule until they are AM=N0 U.S. Nuclear Regulatory comments received may be examined in r-;blc the CommlsIon's Document notified by letter by the NRC' Director Commission. of the OfEice of Nuclear Reactor ACTIOm: Final rule. Room at 1717 H Street. NW., Regulation that. for their particular Washington. D.C. facility. the propam has been SUMMARr. The Nuclear Regulatory The substantive areas of comment can completei. BcaUSe of the Commission Is amending lbrejutions be categorized generally as follows:

considerations just mentioned, that part to require each person licensed to 1 Carcation of Rul* of the prpsd rmlewbl limited the operate a nuclear power reactor to L Applicability of Rule applcabiiy to filities licensed after submit periodically to the Commission 3. Content of TSAR January 2.1963 has been deleted and the revised pages for Its Final Safety 4. Scope of Rule L ming of Submittals rule will apply to all power reactors Analysis Report (FSAR). These revised licnsed to operate.

pages will indicate changes which have L Relation of Rule to Other Rules and been made to reflect information and Tle. R required to be updated by

7. 11 Status of Updated FMAR the rule is the original FSAR submitted analyses submitted to the Commission a Costjeneflt of Rule as part of the application for the or prepared as a result of Commission In response to the comments received, operat u nse. It would not include requirement. The amendment Is being the Commission Is modifying the rle to the subsequent supplements and made to provide an updated reference (a) extend Its applicability to all power amendments to the FSAR or the license document to be used In recurring safety reactors licensed to operate, (b) exclude that may have been submitted either In analyses performed by the licensee, the applicants for operating licenses. (c) response to NRC questions or on the Commission. and other interested clarify the wording of the rule (dl applica or licensee's own initiative parties.. reduce Its impact on power reactor folowing the orinl submittal. These EFFECTIVE DATE: July 22 190. licensees by relexdng some of the time various splements and aendments Not,-The Nuclear Regulatory requirements. and (e) require the Initial must be aopriately incorporated Into ,

Commisslon has submitted this rule to the revision to be a complete FSAR. the original FSAR to create a single.

Comptroller General for such review as may When the proposed rule was complete and integral document. The be appropriate under the Federal Reports published for public comment. its initial revision to be filed should contain Act. as amended. UUS.C. 351L Us date on applicability was limited to those plants those pages From the originally which the reporting requirement of this rule becomes effective. unless advised to the licensed after January 1.1963 in order to submitted TSAR-that are still applicable contrary. accordingly, reflects Inclusion of the exempt five (5)older facilities. The plus new replacement pages that

4Sday period which that statute allows for Commission believed that it would not appropriately incorporate the effects of such review (44 U.S.C. 3Ut(c)(2)). be feasible for these licensees to supplements. amendments and other FOR FURTHER INFORMATION

CONTACT

. implement the rule because there Is no chaes tat have been made. This will Mr. Morton R. Fleishman. Office of integrated document comparable to an result in a dngle complete document Standards Development. US. Nuclear FSAR for their facilities. Since Regulatory Commission. Washington. publication of the proposed rule, the '"Me two Iecttles am*Idian Point Unrt No. I

Commission has Initiated a program in and Humbai&Say Unit No. 3.

D.C. 20555. telephone 31-443-5921.

Federal .Regisr / Vol. 4 No. 92 / Friday. May 9. 1980 1 Rais and Regulations 3061S

being filed, that can then serve as the be at least the same as originally of license amendments and technical baseline for future changes. provided. Minor differences between specification changes are independent Commenters have asked about the actual and projected population figures of the FSAR updating process and once

' proper format to be used when making or other such changes in the site approved would not be subjdct '

'he FSAR submittal. Since the format of environment need not be reported further consideration smply because the the FSAR is not covered by regulation. unless the conclusions of safety SAR Is updated. This. of course, does the rule does not specify a particular analyses reative to public health and not precude the reevaluation of format. ne NRC staff has provided safety are afected and the censee has previous positions based on new guidance for the preparation of FSARs ptrepared new analyses as a result of Information or new considerations. The in Regulatory Cuide I.7 Revision 2. NRC requ.emens material submitted may be reviewed by Standard Format and Content of Safety Commenters have questioned the the NRC staff but will not be formally Analysis Reports for Nuclear Power relation of the proposed FSAR updating approved. The new pages will be Plants" However, many FSARs were requirements to other reporting accepted as representing the licensee's developed prior to any specific guidance requirements such as the Annual position at the time of submittal and will on format The format to be used for the Operating Report and I S0.59(b) be utilized in any subsequent reviews or FSAR revisions is the option of the reporting. It is not the Commission's NRC staff activities concerning that licensee, but the Commission expects intention to require submittal of facility.

that the format will probably be the duplicative reports. The Commission Is After consideration of the comments same as the format of the original FSAM eliminating the requirement for the that were received and other factors, the No analyses other than those already Annual Operating Report ThsaRIl Commission has adopted the prepared or submitted pursuant to NRC reduce significantly the reporting burden amendment to Part 50 as set forth requirements (either originaly with the of licensees. Tere has been no below.

application, or as part of the operating requirement that 50.59(b) reporting be Pursuant to the Atomic Energy Act of license review process, or as required by part of the licensee's Annual Operating 1954 as amended, the Energy

1 50.59 or other NRC requirement. or to ReporL This information generally has. Reorganization Act of 1974. as amended.

support license amendments) are been included in the Annual Operating and section 5 of title S of the United required to be performed by the licensee Report as a convenience, but it could States Code, the following amendment because of this rule. However, analyses have been submitted separately and the to 10 CFR Part 50 Is published as a existing in the FSAR which are known licensee still would have corneplied with document subject to codification.

to be Inaccurate or in error as a result of 1 ,so9(b)which merely requires new analyses performed by the licensee reporting "annually or at such shorter PART 50-DOMESTIC LICENSING OF

pursuant to NRC requirements. would intervals as may be specified In the PRODUCTION AND UTIUZATION

have to be revised. Specialized studies license." Furthermore. the report FACILITIES

provided in the FSAR. such as On required under I 50.59(b) is only "a brief Section 50n1s amended by adding a volcanic hazards or quality assurance, description of such changes. tests. and new paragraph (e)to read as follows:

should include the late information experiments, including a summary of the that has been developed in response to safety evaluation of each." e f 60.71 Mantas. o1 rsords, tkng ot NRC requirements. New analyses (i. 1 50.59(b) reporfti may not be detailed reports.

analyses not previously included in sufficiently to be considered adequate to FSAR) which were required during fulfill the FSAR updating requirement (e) Each person licensed to operate a consideration of unreviewed safety Tle degree of detail required fpr nuclear power reactor pursuant to the questiona 5 technical specification updating the FSAR will be generally provisions of I 501 or 1 5022 shall anges. or other licewsing questions. greater than a "brief descriptionS and a update periodically. as provided in nay be incorporated as appendices or "summary of the safety evaluation." paragraphs (e)[3) and (e)(4) of this ptherwise appropriately inserted within However. there Is nothing that precludes section, the final safety analysis report

_ the FSA.- submitting the I 50.59(b) report along (FSAR) originally submitted as part of Program type material that is with the FSAR update submittal and the application for the operatin license, rteferenced by the FSAR. such as the thus patisfy 1 5059(b) along with to assre that the information Included Quality Assurance Program or the 10.7(e). Parts of the FSAR submittal In the FSAR contains the latest material Emergency Plan, should be referenced may be referenced by the I 509(b) developed. This submittal &hallcontain accurately. If such material has been report. all the changes necessary to reflect revised or amended. the latest revision Several commenters have raised legal Information and analyses submitted to should be referenced. A description of the Commission by the licensee or- physical changes to the facility should questons concerning the proposed rule including questions relative to the prepared by the licensee pursuant to be included in the update after the .purpose of the rule, the implication Commission requirement since the changes have been approved for use and submission of the original FSAR or. as Jk concerning re-reviews, the status of are operable. The level of detail to be cowspleted hearings. and prior license appropriate, the last updated FSAR. The maintained in the updated FSAR should updated FSAR shall be revised to approvals. The rule Is only a reporting requirement to insure that an updated include the effects of: all changes made

'As deflned in I 50.W)(a2). A proposd cian, TSAR will be available. Submittal of In the facility or procedures as test. or experiment hel be deemed to involve an uteoviowed safety quesion (I) if the probabity of updated FSAR pages does not constitute. described in the FSAR: all safety

• ccureCs or the consequence of an accIdent or a licensing action but is only Intended to evaluations performed by the licensee malfunction of equipment Importsnt to safety provide information, It is not intended either In support of requested license previously evaluated inthe safety analysis swport for the purpose of re-reviewing plants. amendments or in support of may be increased or II) if a possibility for an accident or masunction of a different type then any Matters which have been considered conclusions that changes did not involve

'evalusted prenously in the safety analysis Deport previously during hearings will not be an unreviewed safety question: and all may be crtated: oraiii)if the asiDarn of salety as reconsidered as a result of the FSAR analyses of new safety issues performed defined in the basis for any technical specification by or on behalf of the licenste at is reduced.' submittals. Thus. for example, approvals

-1frn r9 yr.#4-ni Pnevicp, I Vnl- 4S. No. 92 / Friday. May 9. 1980 / Rules and Regulations JU:LAU A -p..., On . Vnt. __, No. 9 _ __,, M .

Commission request. The updated - (Sec. ath.. Pub. Law 3-703.68 Stat. OM Sec.

information shall be appropriately 201. Pub. Law 33-43L.8 Stat. 12U4 142 U.S.C.

located within the FSAR. 2201(b). U4t)J.

(1) Revisions containing updated Dated at Washington. D. this lat day of May13980.

infonnation shall be submitted on a replacemept-page basis and shall be For the Nuclear Regulatoy Commispibo.

accomparJed by a list which identifies Samuel 1. cbllU.

the curre;J pages of the FSAR fllowing Secretaryof Lhe CoMMnISSiL

page replacement. One signed priginaI FrDoI4MaU File 5.40

and 12 additional copies of the rpquired MIumo CooM negoo information shall be filed with the Director of Nuclear Reactor Regulation. * ;

U.S. Nuclear Regulatory Cormmision.

Washingtpn. D.C. 20555.

(2) The Fubmittal shall include (1)a certificatipn by a duly authorized officer of the licopsee that either the information accurately presents changes made since thle previous submiattal necrssary to reflect information and analyses ;ubmitted to the Commission or prepared pursuant to Commission requiremlt. or that no such changes were made: and (ii) an identification of chansel riaoe under the provisions of

1 50.59 but not previously submitted to the Commission.

(31(i) A revision of the original FSAR

containing those original pages that are still applicble plus new replacement paees shall be filed within 24 moriths of either July 22.1980, or the date of issuance of the operating license.

whichever is later, and shall bring the FSAR up lo date as of a maximum of O

months prior to the date of filing the revision.

(ii) Not less than 15 days before

1 50.71(c) becomes effetie. the Director of thd Office of Nuclear Reactor Regulation shall notify by letter the licensees of those nuclear power plants initially subject to the NRCs systematic valuation program that they need not comply with thie proviions of this aection while the programlb being condctcd at their plant. The Director of the Office of Nuclear Reactor Regulation will notify by letter the license. of each nuclear power plant belng evaluated when the systematic evaluation program has been conipleted. 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 t montls prior to the date of filing the revisisil

(4) Subsequent revisions shall be ied no less frequently than annually and shall reflect all changes up to a maximun of 6 months prior to the date of filh,.

(5) Each replacement page shall include both a change indicator for the area changed. e.g., a bold line vertically drawn In the marin adjacent to the portion actually anged. and a page change Identification (date of change or change number or both).

Questions and Responses Concerning FSAR Update Rule A. REGULATORY/LEGAL

1. Question: Is the updated FSAR part of the licensed basis of the plant? That is, can the original FSAR, as amended, be set aside and forgotten or is the license still based upon it? E.g., for report- which ing to NRC of deviations from conditions stated in the "FSAR,"

one applies.

Response: The original FSAR, as amended, is still considered to be the licensing basis for the plant. However, as indicated in the rule, the updated FSAR "shall contain all the changes necessary to reflect the sub- information and analyses submitted to the Commiss'ion;... since cer- mission of the original FSAR...." Furthermore, the rule requires tification by the licensee that the "information accurately presents infor- changes made since the previous submittal, necessary to reflect mation and analyses submitted (emphasis added) to the Commission...."

NRC intends and an identification of changes made under IQ-CFR 5 50.59. The to use the updated FSAR in the future for appropriate applications such as reporting of deviations from conditions stated in the "FSAR."

If, as a result of possible audits, the NRC finds that the updated FSAR is not as certified to by the licensee, appropriate enforcement action would be taken.

1

FSAR?

2. Question: Is the updated FSAR to be called the docket file is the final author- Response: The original FSAR and the the updated FSAR, which will be ity if a discrepancy exists although provide the most convenient reference.

referred to.as the updated FSAR, will Question: Who receives update? E.g., do parties to the original

3.

a copy?

proceeding, libraries, etc., receive the licensee is only required Response: As indicated in the rule, There is no intention to send to send the updated FSAR to the NRC.

ufiless such copies are copies to parties to the original proceeding.

regulations. It is planned to place requested in accordance with Commission public document room, the public copies Of.the updated FSAR in the local Technical Information Center document room in Washington,. D. C. the and the Nuclear Safety Information Center.

be used as the technical

4. Question: In the future can the FSAR

specification basis?

are included Response: The bases for the technical specifications If the technical specifi- along with the technical specifications.

may continue to reference the cations have referenced the FSAR, they updated FSAR.

2) has changed, is

5. Question: If environmental information (Chapter the ER or EIS affected in any way?

The rule applies only to the FSAR. The rule imposes no Response:

Report or Environ- requirement to revise or update the Environmental was required, it would be as mental Impact Statement. If a change a result of other regulations.

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6. Question: Relative to the frequency of the updating, what do the words 'no less frequently than annually" mean? .

Response: The time interval between submittals should not exceed

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12 months.

B. FORMAT

1. Question: For multiple unit stations with multiple FSARs:

- Can they be combined into one FSAR, possible with colored pages?

- Must the format for each FSAR be the same?

Response: To the extent that the plants on a multi-unit site are similar and have a good deal of identical information in their FSARs, the FSARs can be combined into a single updated FSAR, for convenience, with differences appropriately identified.

As The formats for each updated FSAR do not have to be the same.

indicated in the supplementary information, the format to be used is the option of the licensee.

2. Question: Do original questions and responses have to be maintained in any particular format, or at all?

Response: The original questions and the responses that were sub- mitted remain in the docket file as part of the record. The re- into sponses to the questions should be appropriately'incorporated the "body" of thp updated FSAR. No separate section is required.

3

3. Question: Is the initial submittal of the updated FSAR treated as the a revision of the original and numbered sequentially following last revision or amendment?

Response The initial submittal of the updated FSAR should be not as treated as i unique document and called the updated FSAR and a sequential revision of the original FSAR. Subsequent changes be should be considered revisions to the updated FSAR and should

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numbered starting with revision No. 1.

4. Question: Are change bars and revision numbers required on the initial update or Is it a "clean" document?

Response: The initial updated FSAR should be a "clean" document without change bars and revision numbers. The subsequent annual revisions would then include the change indicators and page change identification.

S. Question: Can the initial updated FSAR be a complete, new, FSAR

without retaining the old pages?

Response: The initial updated FSAR may be a completely new document without any of the original pages.

C. CONTENT

1. Question: Is the "drawing package" considered part of the FSAR?

Does it need to be updated?

Response: The "drawing package" is not considered part of the FSAR.

Only the drawings that are included in the FSAR should be updated.

4

2. Question: Can one eliminate information no longer applicable to an operating plant - e.g., initial training program, start-up test program, etc., assuming it is in the original FSAR? (Also construc- tion QA program)

Response: Information pertaining to programs described in the original FSAR with amendments, such as the initial training program of and the preoperational test program, should be submitted as part the initial updated FSAR for completeness. The intent here is to locate previously submitted information in one document. Submission of new information is not required. The proposed technical specifi- tech- cations may be eliminated since they have been superseded by nical specifications issued by the Commission.

3. Question: If the original FSAR is in Regulatory Guide 1.70 format, updated?

do comparisons (e.g., to other plants) in Chapter 1 have to be Response: The only changes that should be made should be.to include all material submitted to the NRC. Only an administrative update is required. The licensee should point out that the comparison was con- sidered valid at the time the operating license was issued.

4. Question: Will Security and Emeegency Plans (Chapter 13) be treated separately?

Response; the updated FSAR should reference the Security and Emer- gency Plans that are currently in effect.

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I I

5. Question: Assuming portions of the plant or systems have been modi- fled and designed to codes then currently in effect, how is this addressea in the update?

Response! Identify whatever codes have actually been used to design'

or modify the plant. If older codes were used for certain parts of the plant, it should be so indicated.

6. Question: Assuming the original FSAR contains references that are no longer in.use or acceptable in industry, must they be changed and the affected analysis revised accordingly? (For exa"ple, reference to a Corps of Engineers Technical Document on wave height analysis.)

Response: New analyses do not have to be performed and new refer- ences do not have to be incorporated just to comply with this rule.

Analyses should be revised if safety (i.e., 10 CFR s 50.59) or other Considerations require such revision.

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