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, 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, Zimmer, Washington Public Power Supply System, Shoreham, Satsop, Bailly, Atlantic Nuclear Power Plant, Cherokee, Marble Hill, Hartsville, Phipps Bend, Yellow Creek, Crane
Issue date:	02/26/1981
From:	Eisenhut D G Office of Nuclear Reactor Regulation
To:
References
GL-81-006, NUDOCS 8103230813
Download: ML031080517 (13)

I PLANTS UNDEIR or. REVIEW FF3, ". ' 31 (/evA, 0e Aftkr r176 1.2.3.4.5.6.7.8.9.10.11.12.13.14.15.16.17.18.19.20.21.22.23.24 .25.26.27.28.29.Clinton 1/2 Byron 1/2 Braidwood

1/2 LaSalle 1/2 Midland 1/2 McGuire 2 So. Texas 1/2 Shoreham Waterford Grand Gulf 1/2 Diablo Canyon 1/2 Susquehana

1/2 St. Lucie 2 Summer 1 San Onofre 2/3 Bellefonte

1/2 Watts Bar 1/2 Sequoyah 2 Comanche Peak 1/2 WPPSS-2 Fermi 2 Zimmer I Perry 1/2-Palo Verde Catawba Marble Hill Wolf Creek Callaway 50-461/462

50-454, 455 50-456/457

50-373, 374 50-329,330

50- 370 50-498, 499 50-32 2 50-382 50-416/417

50-275, 323 ,50-387, 388 50-389 50- 39 5 50-361, 362 50-438, 439 50-390, 391 50- 328 50-445, 446 50- 39 7 50-341 50 --3:. 8 50-440, 50-528, 50-413, 50-546, 50-4 82 50-483, 441 529, 530 414 547 486 I 1 R1O323O81 fEH'i -* 1 9YWI PLANTS UNDER (CONSTRUCTION

1.2.3.4.5.6.7.8.9.10.11 .12.13.14.15.16.17.18.19 .20.Cherokee 1/2/3 Beaver Valley 2 St. Lucie 2 Vogtle 1/2 River Bend 1/2 50-491, 50-412 50-3 89 50-424, 50-458, 492, 493 425 459 e Forked River Nine Mile Point 2 Millstone

3.BailJy 2 Limerick 1/2-Hope Creek 1/2 Seabrook 1/2 50-36 3 50-410 50-4 23 50-367 50-352,*50-354, 50-443, Hartsville

1/2/3/4 Phipps Bend 1/2 Yellow Crcek 1/2 WPPSS 1/3/4/5 Harris 1/2/3/4 FNP 50-518, 50-553, 50-566, 50-460, 50-400, 50-437 353 355 444 519, 520, 521 554 567 508, 513, 509 401, 402, 403 ALL POWER REACTOR LICENSEES Docket No. 50-348 Farley Unit 1 Docket No. 50-313 Arkansas Unit 1 Docket No. 50-368 Arkansas Unit 2 Docket No. 50-317 Calvert Cliffs Unit 1 Docket No. 50-318 Calvert Cliffs Unit 2 Docket No. 50-293 Pilgrim Unit 1 Docket No. 50-325 Brunswick Unit 1 Docket No. 50-324 Brunswick Unit 2 Docket No. 50-261 H. B. Robinson Unit 2 Docket No. 50-10 Dresden Unit 1 Docket No. 50-237 Dresden Unit 2 Docket No. 50-249 Dresden Unit 3 Docket No. 50-254 Quad-Cities Unit 1 Docket No. 50-265 Quad-Cities Unit 2 Docket No. 50-295 Zion Unit 1 Docket No. 50-304 Zion Unit 2 Docket No. 50-213 Connecticut Yankee (Haddam Neck)Docket No. 50-3 Indian Point Unit 1 Docket No. 50-247 Indian Point Unit 2 Docket 50-286 Indian Point Unit 3 Docket No. 50-155 Big Rock Point Docket No. 50-255 Palisades Docket No. 50-409 Lacrosse Docket No. 50-269 Oconee Unit 1 Docket No. 50-270 Oconee Unit 2 Docket No. 50-287 Oconee Unit 3 Docket No. 50-334 Beaver Valley Unit 1 Docket No. 50-302 Crystal River 3 Docket No. 50-335 St. Lucie Unit 1 Docket No. 50-250 Turkey Point Unit 3 Docket No. 50-251 Turkey Point Unit 4 Docket No. 50-321 Edwin I. Hatch Unit 1 Docket No. 50-366 Edwin I. Hatch Unit 2 Docket No. 50-315 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 ubr al Reirlster I Vol. 45. No. 92 1 Friday. May L 1980 1 Rules ia Regulations

• lawnt vwwam ..---. -- --- .---- ------

I NUCLEAR REGULATORY

COMMISSION

10 CFR Part 60 Perlodlc Updating of Final Safety Anlysis Reports AM=N0 U.S. Nuclear Regulatory Commission.

ACTIOm: Final rule.SUMMARr. The Nuclear Regulatory Commission Is amending lbrejutions to require each person licensed to operate a nuclear power reactor to submit periodically to the Commission revised pages for Its Final Safety Analysis Report (FSAR). These revised pages will indicate changes which have been made to reflect information and analyses submitted to the Commission or prepared as a result of Commission requirement.

The amendment Is being made to provide an updated reference document to be used In recurring safety analyses performed by the licensee, the Commission.

and other interested parties..EFFECTIVE

DATE: July 22 190.Not,-The Nuclear Regulatory Commisslon has submitted this rule to the Comptroller General for such review as may be appropriate under the Federal Reports Act. as amended. UUS.C. 351L Us date on which the reporting requirement of this rule becomes effective.

unless advised to the contrary.

accordingly, reflects Inclusion of the 4Sday period which that statute allows for such review (44 U.S.C. 3Ut(c)(2)).

FOR FURTHER INFORMATION

CONTACT

.Mr. Morton R. Fleishman.

Office of Standards Development.

US. Nuclear Regulatory Commission.

Washington.

D.C. 20555. telephone

31-443-5921.

• 1UPftKMINTARY

INFORMATIOW.

On November A 197L the Nuclear Regulatory Commission published in the Federal Rjgster (41 FR 49123) notice of proposed Ma making invitig vlnttow suggestions or comments on the proposed sle by December S& 19t A notce f correction and extension of comment period was published In the Federal Register on December 27, 19 141 FR S O In whIch the comment period was extended to January 28.1977.the notices concerned proposed atendments to 10 CFR Part 50 Licening of Production and Utilization Facilities." to require each applicant for.or holder of, a power reactor operating license which would be or was issued after January 1,1963 to submit periodically to the Commission revised pages for its Final Safety Analysis Report (FSAR). These revised pages would Indicate changes made In the facility or the procedures for its operation and any analyses affected by these changes. Thirty-one persons submitted comments regarding the proposed amendments.

The commenters could be roughly divided Into three groups with seventeen supporting the nile with comments, eleven opposed to the rue. and three neutral. Copies of the comments received may be examined in the CommlsIon's r-;blc Document Room at 1717 H Street. NW., Washington.

D.C.The substantive areas of comment can be categorized generally as follows: 1 Carcation of Rul*L Applicability of Rule 3. Content of TSAR 4. Scope of Rule L ming of Submittals L Relation of Rule to Other Rules and 7. 11 Status of Updated FMAR a Costjeneflt of Rule In response to the comments received, the Commission Is modifying the rle to (a) extend Its applicability to all power reactors licensed to operate, (b) exclude applicants for operating licenses. (c)clarify the wording of the rule (dl reduce Its impact on power reactor licensees by relexdng some of the time requirements.

and (e) require the Initial revision to be a complete FSAR.When the proposed rule was published for public comment. its applicability was limited to those plants licensed after January 1.1 963 in order to exempt five (5) older facilities.

The Commission believed that it would not be feasible for these licensees to implement the rule because there Is no integrated document comparable to an FSAR for their facilities.

Since publication of the proposed rule, the Commission has Initiated a program in which theNRCstaff is making a systematic safety evaluation of eleven (11) nuclear power facilities licensed for operation before 172. The purpose of this systmatle evaluation program ISEP) Is to determine and document the degree to which the eleven (p1) facilitlms mec t licensing requirements for new plants. Of the tva (5) plants li sd por o January 1 1983 that are si lI sed to operate, three (3) are Included In the SEP. Th remaining two (23 plants.' which presently are shut down, will be subject to the provisions of the nrle as long as their licenses authorize operation The licensees participating in the SEP probably will be requested to supply a considerable amount of Information during the program. Requiring them In addition.

to update their FSARs could prove to be excessively burdensome and cauld result In duplication of reports.The Information generated during the program and the manner in which it i collated wM result in a completed FSAR at the concluson of the program For these reasons licensees of facilities being subjected by the NRC to a systematic evaluation program will not be required to comply with the provisions of thfs rule until they are notified by letter by the NRC' Director of the OfEice of Nuclear Reactor Regulation that. for their particular facility.

the propam has been completei.

BcaUSe of the considerations just mentioned, that part of the prpsd rmlewbl limited the applcabiiy to filities licensed after January 2.1963 has been deleted and the rule will apply to all power reactors licnsed to operate.Tle. R required to be updated by the rule is the original FSAR submitted as part of the application for the operat u nse. It would not include the subsequent supplements and amendments to the FSAR or the license that may have been submitted either In response to NRC questions or on the applica or licensee's own initiative folowing the orinl submittal.

These various splements and aendments must be aopriately incorporated Into , the original FSAR to create a single.complete and integral document.

The initial revision to be filed should contain those pages From the originally submitted TSAR-that are still applicable plus new replacement pages that appropriately incorporate the effects of supplements.

amendments and other chaes tat have been made. This will result in a dngle complete document'"Me two Iecttles am*Idian Point Unrt No. I and Humbai& Say Unit No. 3.

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

3061S being filed, that can then serve as the baseline for future changes.Commenters have asked about the' proper format to be used when making'he FSAR submittal.

Since the format of the FSAR is not covered by regulation.

the rule does not specify a particular format. ne NRC staff has provided guidance for the preparation of FSARs in Regulatory Cuide I.7 Revision 2.Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants" However, many FSARs were developed prior to any specific guidance on format The format to be used for the 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 FSAM No analyses other than those already prepared or submitted pursuant to NRC requirements (either originaly with the application, or as part of the operating license review process, or as required by 1 50.59 or other NRC requirement.

or to support license amendments)

are required to be performed by the licensee because of this rule. However, analyses existing in the 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 late information that has been developed in response to NRC requirements.

New analyses (i.analyses not previously included in FSAR) which were required during consideration of unreviewed safety questiona 5 technical specification anges. or other licewsing questions.

nay be incorporated as appendices or ptherwise appropriately inserted within_ the FSA.-Program type material that is r teferenced by the FSAR. such as the Quality Assurance Program or the Emergency Plan, should be referenced accurately.

If such material has been revised or amended. the latest revision should be referenced.

A description of physical changes to the facility should be included in the update after the changes have been approved for use and are operable.

The level of detail to be maintained in the updated FSAR should'As deflned in I 50.W)(a2).

A proposd cian, test. or experiment hel be deemed to involve an uteoviowed safety quesion (I) if the probabity of*ccureCs or the consequence of an accIdent or malfunction of equipment Importsnt to safety previously evaluated in the safety analysis swport may be increased or II) if a possibility for an accident or masunction of a different type then any'evalusted prenously in the safety analysis Deport may be crtated: or aiii) if the asiDarn of salety as defined in the basis for any technical specification is reduced.'be at least the same as originally provided.

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 reative to public health and safety are afected and the censee has ptrepared new analyses as a result of NRC requ.emens Commenters have questioned the relation of the proposed FSAR updating requirements to other reporting requirements such as the Annual Operating Report and I S0.59(b)reporting.

It is not the Commission's intention to require submittal of duplicative reports. The Commission Is eliminating the requirement for the Annual Operating Report Ths aRIl reduce significantly the reporting burden of licensees.

Tere has been no requirement that 50.59(b) reporting be part of the licensee's Annual Operating ReporL This information generally has.been included in the Annual Operating Report as a convenience, but it could have been submitted separately and the licensee still would have corneplied with 1 ,so9(b) which merely requires reporting "annually or at such shorter intervals as may be specified In the license." Furthermore.

the report required under I 50.59(b) is only "a brief description of such changes. tests. and experiments, including a summary of the safety evaluation of each." e 1 50.59(b) reporfti may not be detailed sufficiently to be considered adequate to fulfill the FSAR updating requirement Tle degree of detail required fpr updating the FSAR will be generally greater than a "brief descriptionS

and a"summary of the safety evaluation." However. there Is nothing that precludes submitting the I 50.59(b) report along with the FSAR update submittal and thus patisfy 1 5059(b) along with 10.7(e). Parts of the FSAR submittal may be referenced by the I 509(b)report.Several commenters have raised legal questons concerning the proposed rule including questions relative to the.purpose of the rule, the implication concerning re-reviews, the status of cowspleted hearings.

and prior license approvals.

The rule Is only a reporting requirement to insure that an updated TSAR 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.Matters which have been considered previously during hearings will not be reconsidered as a result of the FSAR submittals.

Thus. for example, approvals of license amendments and technical specification changes are independent of the FSAR updating process and once approved would not be subjdct 'further consideration smply because the SAR Is updated. This. of course, does not precude the reevaluation of previous positions based on new Information or new considerations.

The material submitted may be reviewed by the NRC staff but will not be formally approved.

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 concerning that facility.After consideration of the comments that were received and other factors, the Commission has adopted the amendment to Part 50 as set forth below.Pursuant to the Atomic Energy Act of 1954 as amended, the Energy Reorganization Act of 1974. as amended.and section 5 of title S of the United States Code, the following amendment to 10 CFR Part 50 Is published as a document subject to codification.

PART 50-DOMESTIC

LICENSING

OF PRODUCTION

AND UTIUZATION

FACILITIES

Section 50n 1s amended by adding a new paragraph (e) to read as follows: f 60.71 Mantas. o1 rsords, tkng ot reports.(e) Each person licensed to operate a nuclear power reactor pursuant to the provisions of I 501 or 1 5022 shall update periodically.

as provided in paragraphs (e)[3) and (e)(4) of this section, the final safety analysis report (FSAR) originally submitted as part of the application for the operatin license, to assre that the information Included In the FSAR contains the latest material developed.

This submittal

&hall 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 licenste at Jk yr.#4-ni Pnevicp, I Vnl- 4S. No. 92 / Friday. May 9. 1980 / Rules and Regulations

-1frn r9 JU:LAU A On -p..., .Vnt. __, No. 9 _ __,, M .Commission request. The updated information shall be appropriately located within the FSAR.(1) Revisions containing updated infonnation shall be submitted on a replacemept-page basis and shall be accomparJed by a list which identifies the curre;J pages of the FSAR fllowing page replacement.

One signed priginaI and 12 additional copies of the rpquired 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).-(Sec. ath.. Pub. Law 3-703.68 Stat. OM Sec.201. Pub. Law 33-43L .8 Stat. 12U4 142 U.S.C.2201(b). U4t)J.Dated at Washington.

D. this lat day of May13980.For the Nuclear Regulatoy Commispibo.

Samuel 1. cbllU.Secretary of Lhe CoMMnISSiL

FrDoI4MaU

File 5.40 MIumo CooM negoo* ;

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-ing to NRC of deviations from conditions stated in the "FSAR," which 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 information and analyses submitted to the Commiss'ion;...

since the sub-mission of the original FSAR...." Furthermore, the rule requires cer-tification by the licensee that the "information accurately presents changes made since the previous submittal, necessary to reflect infor-mation and analyses submitted (emphasis added) to the Commission...." and an identification of changes made under IQ-CFR 5 50.59. The NRC intends 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

2. Question:

Is the updated FSAR to be called the FSAR?Response:

The original FSAR and the docket file is the final author-ity if a discrepancy exists although the updated FSAR, which will be referred to.as the updated FSAR, will provide the most convenient reference.

3. Question:

Who receives update? E.g., do parties to the original proceeding, libraries, etc., receive a copy?Response:

As indicated in the rule, the licensee is only required to send the updated FSAR to the NRC. There is no intention to send copies to parties to the original proceeding.

ufiless such copies are requested in accordance with Commission regulations.

It is planned to place copies Of.the updated FSAR in the local public document room, the public document room in Washington,.

D. C. the Technical Information Center and the Nuclear Safety Information Center.4. Question:

In the future can the FSAR be used as the technical specification basis?Response:

The bases for the technical specifications are included along with the technical specifications.

If the technical specifi-cations have referenced the FSAR, they may continue to reference the updated FSAR.5. Question:

If environmental information (Chapter 2) has changed, is the ER or EIS affected in any way?Response:

The rule applies only to the FSAR. The rule imposes no requirement to revise or update the Environmental Report or Environ-mental Impact Statement.

If a change was required, it would be as a result of other regulations.

2

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 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.

The formats for each updated FSAR do not have to be the same. As 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-sponses to the questions should be appropriately'incorporated into the "body" of thp updated FSAR. No separate section is required.3

3. Question:

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

Response The initial submittal of the updated FSAR should be treated as i unique document and called the updated FSAR and not as a sequential revision of the original FSAR. Subsequent changes should be considered revisions to the updated FSAR and should be -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 and the preoperational test program, should be submitted as part of 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-cations may be eliminated since they have been superseded by tech-nical specifications issued by the Commission.

3. Question:

If the original FSAR is in Regulatory Guide 1.70 format, do comparisons (e.g., to other plants) in Chapter 1 have to be updated?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.5 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.'6