NRC-99-0071, Comment Supporting Draft RG DG-1083, Content of Ufsar,Iaw 10CFR50.71(e), Dtd Dec 1998

Comment Supporting Draft RG DG-1083, Content of Ufsar,Iaw 10CFR50.71(e), Dtd Dec 1998

ML20207D291
Person / Time
Site:	Fermi
Issue date:	04/30/1999
From:	Peterson N DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
CON-NRC-99-0071, CON-NRC-99-71, FRN-64FR13833, RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-*****, TASK-RE 64FR13833-00012, 64FR13833-12, NUDOCS 9906030291
Download: ML20207D291 (2)

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Rules and Directives Branch Office of Administration U. S. Nuclear Regulatory Commission )

j Washington D C 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) Federal Register, Volume 64, Number 54

" Draft Regulatory guide (DG)-1083 " Content of the Updated Final Safety analysis Report in Accordance with 10CFR 50.71(c)" dated December,1998  !

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Subject:

Detroit Edison Comments on " Draft Regulatory Guide (DG)-1683

" Content of the Updated Final Safety Analysis Report in Accordance with 10CFR 50.71(e)"

Detroit Edison fully agrees with the issuance of this Regulatory Guide that endorses NEI 98 03. The guidance provided by this document will be particularly useful in establishing an process for the voluntary removal of excessive detail from FSAR's.

Detroit Edison believes that such a process will result in saving licensee resources with no reduction in the NRC's ability to monitor plant changes that have any safety or risk significance.

In the Federal Register Notice the NRC stairexpressed a concem regarding the removal ofinfonnation and proposed the following addition to Section A2 of NEI 98-03:

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"It is the intent of this guideline to help licensees remove unimportant

\f information from UFSARs such as excessive detail, obsolete, or redundant ]

information. This guideline is not intended to be used to remove information from UFSARs regarding SSCs that insights from operating experience or probabilistic risk assessments would indicate are risk significant."

9906030291 990430 PDR REGGD 01 XXX C PDR ,,

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'y USNRC T NRC-99-0071 Page 2 As stated above, Detroit Edison believes that having a process, that is recognized and acceptable to the NRC, will be a significant improvement. While we understand the staffs concern that this process could be used to remove important information 1

related to risk significant SSC's described in the FSAR, we believe that this concern is not warranted based on controls over deletions established in other section 98-03; specifically Section A.4.1. For example, the four types of excessive detail )

described in A.4.1 along with some specific examples such as component model numbers, specific motor hp ratings for MOV's, etc. adequately communicate the 1 o intent of the guidance on removal. It is clear to licensees that information important to the description of the facility or presentation ofit's safety analysis could not be removed. In addition, the provisions requiring reporting ofinformation removed, would allow the NRC staff to readily monitor the implementation of this process.

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Should you have any questions or require additional information, please contact me at (734) 586-4258.

1 Sincerely, Norman K. Peterson Director- Nuclear Licensing i

cc: A. J. Kugler A. Vegel NRC Resident Office l Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission Nuclear Energy Institute - A. Pietrangelo

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