ML19326D287

Forwards Util Proposed Position Re FSAR Format & Content, Allowing Appropriate Exceptions to Fsar,Revision 2,per 760113 Meeting Discussions

ML19326D287
Person / Time
Site:	Midland
Issue date:	03/03/1976
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Boyd R Office of Nuclear Reactor Regulation
References
HOWE-40-76, NUDOCS 8006090722
Download: ML19326D287 (3)

Text

. L '

n -

~ ~ ~ f. h x L0il50Mcio

n -,,, -

d il 5 b Stephen H. Howell Vice Presutent G-*aa*e7 O Y ebbh 0 $$ ft General Offices: 212 West MicNgan Avenuer acks 4 an 49201 f, '

/g March 3, 1976 Hove-40-76 V

y8 hOdM p{

dJ 19 7 g ,

b9 -

So-330 70 -

Mr. Roger Boyd, Director "

S t k5 -

Division of Project Management //

Office of Nuclear Reactor Regulation  %

US Nuclear Regulatory Con =ission N Washington, DC 20555 g

MIDIAND PIANT FINAL SAFETY ANALYSIS REPORT '

FILE: 0505 SERIAL: 2181 -

During the January 13,19'i15 meeting with members of the NRC staff, we discussed the content of the Midland Plant FSAR relative to Revision 2 of the Standard For-mat and Content of Safety Analysis Reports. As indicated during the meeting, a significant amount of information required by Revision 2 of the standard format is not available for design, manufacturing or construction activities completed to date. Significant re-analysis and development of information on completed activities would be necessary to fully comply with Revision 2.

The Midland FSAR will be prepared in accordance with the required Revision 2 for-mat; however, we request that the attached " Applicant's Proposed Staff Position - l FSAR Format and Content" be accepted to allow appropriate exceptions to the con-tent required by Revision 2. The issuance of a position on FSAR format and con-tent will be consistent with the policy followed by the NRC in releasing the August 4,1975 Staff Position on Implementation of Regulatory Guides.

Rather than submit a specific list of exceptions to Revision 2 content for staff consideration as discussed in the January 13, 1976 meeting, we suggest the issu-ance of a policy statement as the initial step. A pretendering assessment of specific exceptions can then be explored with the staff.

Your early response vill be appreciated so that our FSAR preparation can proceed with an optimum effort.

,k mA wv LV '

8006090 7

a , . _ - _ _ _ _ _

v f.

n '

m

6. '

March 1, 1976 APPLICANT'S PROPOSED STAFF POSITION FSAR FORMAT AND CONTENT FOR THE MIDLAND PIANT UNITS 1 AND 2 I. 'Ibe staff's review and evaluation of the operating license application for the Midland Plant will be performed using the staff's published Standard Review Plans, with dM consideration being given to the status of the design, procurement and construction of the plant at the time the accep-tance criteria contained in those plans became available.

II. The FSAR shall conform to the Format contained in Regulatory Guide 1 70, Rev 2, Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants - LWR Edition.

III. With respect to Content, the FSAR shall contain information required by Rev 2 of Regulatory Guide 1.70 with exceptions allowed under the following conditions.

A. Exceptions to Rev 2 content will be permitted for a specific require-ment if all three of the following conditions are met:

1. The information is not available due to completion of associated engineering, manufacturing or construction prior to issuance of Rev 2 to Regulatory Guide 1.70.

2. The information would require significant engineering analysis, testing, inspection, etc, to develop.

3. The information is not required for the staff's evaluation of an item considered as absolutely essential for safety. Management will review these requirements to assure that they have been justi-fied as absolutely essential for safety.

B. If the required information is covered by a Consumers Power, Bechtel or B&W Topical Report approved by the NRC, additional analysis beyond that contained in the Topical Report is not required.

C. If the subject has been resolved during the review by the staff to determine applicability of new Regulatory Guides for the Midland Plant, additional analysis beyond that contained in the Applicant's final Regulatory Guide position is not required.