NRC Generic Letter 1981-06
IPLANTS UNDEIR or. REVIEWFF3, ". ' 31(/evA, 0e Aftkrr1761.2.3.4.5.6.7.8.9.10.11.12.13.14.15.16.17.18.19.20.21.22.23.24 .25.26.27.28.29.Clinton 1/2Byron 1/2Braidwood 1/2LaSalle 1/2Midland 1/2McGuire 2So. Texas 1/2ShorehamWaterfordGrand Gulf 1/2Diablo Canyon 1/2Susquehana 1/2St. Lucie 2Summer 1San Onofre 2/3Bellefonte 1/2Watts Bar 1/2Sequoyah 2Comanche Peak 1/2WPPSS-2Fermi 2Zimmer IPerry 1/2-Palo VerdeCatawbaMarble HillWolf CreekCallaway50-461/46250-454, 45550-456/45750-373, 37450-329,33050- 37050-498, 49950-32 250-38250-416/41750-275, 323,50-387, 38850-38950- 39 550-361, 36250-438, 43950-390, 39150- 32850-445, 44650- 39 750-34150 --3:. 850-440,50-528,50-413,50-546,50-4 8250-483,441529, 530414547486I 1 R1O323O81 fEH'i -* 1 9YWIPLANTS UNDER (CONSTRUCTION1.2.3.4.5.6.7.8.9.10.11 .12.13.14.15.16.17.18.19 .20.Cherokee 1/2/3Beaver Valley 2St. Lucie 2Vogtle 1/2River Bend 1/250-491,50-41250-3 8950-424,50-458,492, 493425459eForked RiverNine Mile Point 2Millstone 3.BailJy 2Limerick 1/2-Hope Creek 1/2Seabrook 1/250-36 350-41050-4 2350-36750-352,*50-354,50-443,Hartsville 1/2/3/4Phipps Bend 1/2Yellow Crcek 1/2WPPSS 1/3/4/5Harris 1/2/3/4FNP50-518,50-553,50-566,50-460,50-400,50-437353355444519, 520, 521554567508, 513, 509401, 402, 403 ALL POWER REACTOR LICENSEESDocket No. 50-348Farley Unit 1Docket No. 50-313Arkansas Unit 1Docket No. 50-368Arkansas Unit 2Docket No. 50-317Calvert Cliffs Unit 1Docket No. 50-318Calvert Cliffs Unit 2Docket No. 50-293Pilgrim Unit 1Docket No. 50-325Brunswick Unit 1Docket No. 50-324Brunswick Unit 2Docket No. 50-261H. B. Robinson Unit 2Docket No. 50-10Dresden Unit 1Docket No. 50-237Dresden Unit 2Docket No. 50-249Dresden Unit 3Docket No. 50-254Quad-Cities Unit 1Docket No. 50-265Quad-Cities Unit 2Docket No. 50-295Zion Unit 1Docket No. 50-304Zion Unit 2Docket No. 50-213Connecticut Yankee (Haddam Neck)Docket No. 50-3Indian Point Unit 1Docket No. 50-247Indian Point Unit 2Docket 50-286Indian Point Unit 3Docket No. 50-155Big Rock PointDocket No. 50-255PalisadesDocket No. 50-409LacrosseDocket No. 50-269Oconee Unit 1Docket No. 50-270Oconee Unit 2Docket No. 50-287Oconee Unit 3Docket No. 50-334Beaver Valley Unit 1Docket No. 50-302Crystal River 3Docket No.50-335St. Lucie Unit 1Docket No. 50-250Turkey Point Unit 3Docket No. 50-251Turkey Point Unit 4Docket No. 50-321Edwin I. Hatch Unit 1Docket No. 50-366Edwin I. Hatch Unit 2Docket No. 50-315D. C. Cook Unit 1 UNITED STATESNUCLEAR REGULATORY COMMISSIONg aWASHINGTON, D. C. 205February 26, 1981ALL CONSTRUCTION PERMIT HOLDERS AND APPLICANTS FOR OPERATINQ MICEN$ESGentlemen: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 therule in the Federal Register on May 9, 1980. The rule became effectiveon July 22, 1980.Although this new rule applies to holders of operating licenses for powerreactors, we believe your organization should be aware of it, since, within24 months after issuance of an operating license or July 22, 1982, whicheveris later, the original FSAR submitted as a part of the OL application mustbe updated in the specific manner provided in the rule. Thereafter, it mustbe updated at least annually. Each update must reflect all changes up to sixmonths prior to the filing of the update.Although the rule itself is self-explanatory, several questions have beenasked regarding the FSAR's legal status, format and content, and we haveprovided the enclosed guidance.Further questions should be directed to the Project Manager for your facility.\ ncerely,Darrell G irectorDivision of Licensing
Enclosure:
As stated ubr al Reirlster I Vol. 45. No. 92 1 Friday. May L 1980 1 Rules ia Regulations* lawntvwwam ..---. -- --- .---- ------ INUCLEAR REGULATORYCOMMISSION10 CFR Part 60Perlodlc Updating of Final SafetyAnlysis ReportsAM=N0 U.S. Nuclear RegulatoryCommission.ACTIOm: Final rule.SUMMARr. The Nuclear RegulatoryCommission Is amending lbrejutionsto require each person licensed tooperate a nuclear power reactor tosubmit periodically to the Commissionrevised pages for Its Final SafetyAnalysis Report (FSAR). These revisedpages will indicate changes which havebeen made to reflect information andanalyses submitted to the Commissionor prepared as a result of Commissionrequirement. The amendment Is beingmade to provide an updated referencedocument to be used In recurring safetyanalyses performed by the licensee, theCommission. and other interestedparties..EFFECTIVE DATE: July 22 190.Not,-The Nuclear RegulatoryCommisslon has submitted this rule to theComptroller General for such review as maybe appropriate under the Federal ReportsAct. as amended. UUS.C. 351L Us date onwhich the reporting requirement of this rulebecomes effective. unless advised to thecontrary. accordingly, reflects Inclusion of the4Sday period which that statute allows forsuch review (44 U.S.C. 3Ut(c)(2)).FOR FURTHER INFORMATION
CONTACT
.Mr. Morton R. Fleishman. Office ofStandards Development. US. NuclearRegulatory Commission. Washington.D.C. 20555. telephone 31-443-5921.*1UPftKMINTARY INFORMATIOW. OnNovember A 197L the NuclearRegulatory Commission published in theFederal Rjgster (41 FR 49123) noticeof proposed Ma making invitig vlnttowsuggestions or comments on theproposed sle by December S& 19t Anotce f correction and extension ofcomment period was published In theFederal Register on December 27, 19141 FR S O In whIch the commentperiod was extended to January 28.1977.the notices concerned proposedatendments to 10 CFR Part 50Licening of Production and UtilizationFacilities." to require each applicant for.or holder of, a power reactor operatinglicense which would be or was issuedafter January 1,1963 to submitperiodically to the Commission revisedpages for its Final Safety AnalysisReport (FSAR). These revised pageswould Indicate changes made In thefacility or the procedures for itsoperation and any analyses affected bythese changes. Thirty-one personssubmitted comments regarding theproposed amendments. The commenterscould be roughly divided Into threegroups with seventeen supporting thenile with comments, eleven opposed tothe rue. and three neutral. Copies of thecomments received may be examined inthe CommlsIon's r-;blc DocumentRoom at 1717 H Street. NW.,Washington. D.C.The substantive areas of comment canbe categorized generally as follows:1 Carcation of Rul*L Applicability of Rule3. Content of TSAR4. Scope of RuleL ming of SubmittalsL Relation of Rule to Other Rules and7. 11 Status of Updated FMARa Costjeneflt of RuleIn response to the comments received,the Commission Is modifying the rle to(a) extend Its applicability to all powerreactors licensed to operate, (b) excludeapplicants for operating licenses. (c)clarify the wording of the rule (dlreduce Its impact on power reactorlicensees by relexdng some of the timerequirements. and (e) require the Initialrevision to be a complete FSAR.When the proposed rule waspublished for public comment. itsapplicability was limited to those plantslicensed after January 1.1 963 in order toexempt five (5) older facilities. TheCommission believed that it would notbe feasible for these licensees toimplement the rule because there Is nointegrated document comparable to anFSAR for their facilities. Sincepublication of the proposed rule, theCommission has Initiated a program inwhich theNRCstaff is making asystematic safety evaluation of eleven(11) nuclear power facilities licensed foroperation before 172. The purpose ofthis systmatle evaluation programISEP) Is to determine and document thedegree to which the eleven (p1) facilitlmsmec t licensing requirements fornew plants. Of the tva (5) plantsli sd por o January 1 1983 that aresi lI sed to operate, three (3) areIncluded In the SEP. Th remaining two(23 plants.' which presently are shutdown, will be subject to the provisionsof the nrle as long as their licensesauthorize operationThe licensees participating in the SEPprobably will be requested to supply aconsiderable amount of Informationduring the program. Requiring them Inaddition. to update their FSARs couldprove to be excessively burdensome andcauld result In duplication of reports.The Information generated during theprogram and the manner in which it icollated wM result in a completed FSARat the concluson of the program Forthese reasons licensees of facilitiesbeing subjected by the NRC to asystematic evaluation program will notbe required to comply with theprovisions of thfs rule until they arenotified by letter by the NRC' Directorof the OfEice of Nuclear ReactorRegulation that. for their particularfacility. the propam has beencompletei. BcaUSe of theconsiderations just mentioned, that partof the prpsd rmlewbl limited theapplcabiiy to filities licensed afterJanuary 2.1963 has been deleted and therule will apply to all power reactorslicnsed to operate.Tle. R required to be updated bythe rule is the original FSAR submittedas part of the application for theoperat u nse. It would not includethe subsequent supplements andamendments to the FSAR or the licensethat may have been submitted either Inresponse to NRC questions or on theapplica or licensee's own initiativefolowing the orinl submittal. Thesevarious splements and aendmentsmust be aopriately incorporated Into ,the original FSAR to create a single.complete and integral document. Theinitial revision to be filed should containthose pages From the originallysubmitted TSAR-that are still applicableplus new replacement pages thatappropriately incorporate the effects ofsupplements. amendments and otherchaes tat have been made. This willresult in a dngle complete document'"Me two Iecttles am*Idian Point Unrt No. Iand Humbai& Say Unit No. Federal .Regisr / Vol. 4 No. 92 / Friday. May 9. 1980 1 Rais and Regulations3061Sbeing filed, that can then serve as thebaseline for future changes.Commenters have asked about the' proper format to be used when making'he FSAR submittal. Since the format ofthe FSAR is not covered by regulation.the rule does not specify a particularformat. ne NRC staff has providedguidance for the preparation of FSARsin Regulatory Cuide I.7 Revision 2.Standard Format and Content of SafetyAnalysis Reports for Nuclear PowerPlants" However, many FSARs weredeveloped prior to any specific guidanceon format The format to be used for theFSAR revisions is the option of thelicensee, but the Commission expectsthat the format will probably be thesame as the format of the original FSAMNo analyses other than those alreadyprepared or submitted pursuant to NRCrequirements (either originaly with theapplication, or as part of the operatinglicense review process, or as required by1 50.59 or other NRC requirement. or tosupport license amendments) arerequired to be performed by the licenseebecause of this rule. However, analysesexisting in the FSAR which are knownto be Inaccurate or in error as a result ofnew analyses performed by the licenseepursuant to NRC requirements. wouldhave to be revised. Specialized studiesprovided in the FSAR. such as Onvolcanic hazards or quality assurance,should include the late informationthat has been developed in response toNRC requirements. New analyses (i.analyses not previously included inFSAR) which were required duringconsideration of unreviewed safetyquestiona5 technical specificationanges. or other licewsing questions.nay be incorporated as appendices orptherwise appropriately inserted within_ the FSA.-Program type material that isr teferenced by the FSAR. such as theQuality Assurance Program or theEmergency Plan, should be referencedaccurately. If such material has beenrevised or amended. the latest revisionshould be referenced. A description ofphysical changes to the facility shouldbe included in the update after thechanges have been approved for use andare operable. The level of detail to bemaintained in the updated FSAR should'As deflned in I 50.W)(a2). A proposd cian,test. or experiment hel be deemed to involve anuteoviowed safety quesion (I) if the probabity of*ccureCs or the consequence of an accIdent ormalfunction of equipment Importsnt to safetypreviously evaluated in the safety analysis swportmay be increased or II) if a possibility for anaccident or masunction of a different type then any'evalusted prenously in the safety analysis Deportmay be crtated: or aiii) if the asiDarn of salety asdefined in the basis for any technical specificationis reduced.'be at least the same as originallyprovided. Minor differences betweenactual and projected population figuresor other such changes in the siteenvironment need not be reportedunless the conclusions of safetyanalyses reative to public health andsafety are afected and the censee hasptrepared new analyses as a result ofNRC requ.emensCommenters have questioned therelation of the proposed FSAR updatingrequirements to other reportingrequirements such as the AnnualOperating Report and I S0.59(b)reporting. It is not the Commission'sintention to require submittal ofduplicative reports. The Commission Iseliminating the requirement for theAnnual Operating Report Ths aRIlreduce significantly the reporting burdenof licensees. Tere has been norequirement that 50.59(b) reporting bepart of the licensee's Annual OperatingReporL This information generally has.been included in the Annual OperatingReport as a convenience, but it couldhave been submitted separately and thelicensee still would have corneplied with1 ,so9(b) which merely requiresreporting "annually or at such shorterintervals as may be specified In thelicense." Furthermore. the reportrequired under I 50.59(b) is only "a briefdescription of such changes. tests. andexperiments, including a summary of thesafety evaluation of each." e1 50.59(b) reporfti may not be detailedsufficiently to be considered adequate tofulfill the FSAR updating requirementTle degree of detail required fprupdating the FSAR will be generallygreater than a "brief descriptionS and a"summary of the safety evaluation."However. there Is nothing that precludessubmitting the I 50.59(b) report alongwith the FSAR update submittal andthus patisfy 1 5059(b) along with10.7(e). Parts of the FSAR submittalmay be referenced by the I 509(b)report.Several commenters have raised legalquestons concerning the proposed ruleincluding questions relative to the.purpose of the rule, the implicationconcerning re-reviews, the status ofcowspleted hearings. and prior licenseapprovals. The rule Is only a reportingrequirement to insure that an updatedTSAR will be available. Submittal ofupdated FSAR pages does not constitute.a licensing action but is only Intended toprovide information, It is not intendedfor the purpose of re-reviewing plants.Matters which have been consideredpreviously during hearings will not bereconsidered as a result of the FSARsubmittals. Thus. for example, approvalsof license amendments and technicalspecification changes are independentof the FSAR updating process and onceapproved would not be subjdct 'further consideration smply because theSAR Is updated. This. of course, doesnot precude the reevaluation ofprevious positions based on newInformation or new considerations. Thematerial submitted may be reviewed bythe NRC staff but will not be formallyapproved. The new pages will beaccepted as representing the licensee'sposition at the time of submittal and willbe utilized in any subsequent reviews orNRC staff activities concerning thatfacility.After consideration of the commentsthat were received and other factors, theCommission has adopted theamendment to Part 50 as set forthbelow.Pursuant to the Atomic Energy Act of1954 as amended, the EnergyReorganization Act of 1974. as amended.and section 5 of title S of the UnitedStates Code, the following amendmentto 10 CFR Part 50 Is published as adocument subject to codification.PART 50-DOMESTIC LICENSING OFPRODUCTION AND UTIUZATIONFACILITIESSection 50n 1s amended by adding anew paragraph (e) to read as follows:f 60.71 Mantas. o1 rsords, tkng otreports.(e) Each person licensed to operate anuclear power reactor pursuant to theprovisions of I 501 or 1 5022 shallupdate periodically. as provided inparagraphs (e)[3) and (e)(4) of thissection, the final safety analysis report(FSAR) originally submitted as part ofthe application for the operatin license,to assre that the information IncludedIn the FSAR contains the latest materialdeveloped. This submittal &hall containall the changes necessary to reflectInformation and analyses submitted tothe Commission by the licensee or-prepared by the licensee pursuant toCommission requirement since thesubmission of the original FSAR or. asappropriate, the last updated FSAR. Theupdated FSAR shall be revised toinclude the effects of: all changes madeIn the facility or procedures asdescribed in the FSAR: all safetyevaluations performed by the licenseeeither In support of requested licenseamendments or in support ofconclusions that changes did not involvean unreviewed safety question: and allanalyses of new safety issues performedby or on behalf of the licenste atJk yr.#4-ni Pnevicp, I Vnl- 4S. No. 92 / Friday. May 9. 1980 / Rules and Regulations-1frn r9JU:LAU A On -p..., .Vnt. __, No. 9 _ __,, M .Commission request. The updatedinformation shall be appropriatelylocated within the FSAR.(1) Revisions containing updatedinfonnation shall be submitted on areplacemept-page basis and shall beaccomparJed by a list which identifiesthe curre;J pages of the FSAR fllowingpage replacement. One signed priginaIand 12 additional copies of the rpquiredinformation shall be filed with theDirector of Nuclear Reactor Regulation.U.S. Nuclear Regulatory Cormmision.Washingtpn. D.C. 20555.(2) The Fubmittal shall include (1) acertificatipn by a duly authorized officerof the licopsee that either theinformation accurately presents changesmade since thle previous submiattalnecrssary to reflect information andanalyses ;ubmitted to the Commissionor prepared pursuant to Commissionrequiremlt. or that no such changeswere made: and (ii) an identification ofchansel riaoe under the provisions of1 50.59 but not previously submitted tothe Commission.(31(i) A revision of the original FSARcontaining those original pages that arestill applicble plus new replacementpaees shall be filed within 24 moriths ofeither July 22.1980, or the date ofissuance of the operating license.whichever is later, and shall bring theFSAR up lo date as of a maximum of Omonths prior to the date of filing therevision.(ii) Not less than 15 days before1 50.71(c) becomes effetie. theDirector of thd Office of Nuclear ReactorRegulation shall notify by letter thelicensees of those nuclear power plantsinitially subject to the NRCs systematicvaluation program that they need notcomply with thie proviions of thisaection while the programlb beingcondctcd at their plant. The Director ofthe Office of Nuclear Reactor Regulationwill notify by letter the license. of eachnuclear power plant belng evaluatedwhen the systematic evaluation programhas been conipleted. Within 24 monthsafter receipt of this notification, thelicensee shall file a complete FSARwhich is up to date as of a maximum oft montls prior to the date of filing therevisisil(4) Subsequent revisions shall be iedno less frequently than annually andshall reflect all changes up to amaximun of 6 months prior to the dateof filh,.(5) Each replacement page shallinclude both a change indicator for thearea changed. e.g., a bold line verticallydrawn In the marin adjacent to theportion actually anged. and a pagechange Identification (date of change orchange 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 ofMay13980.For the Nuclear Regulatoy Commispibo.Samuel 1. cbllU.Secretary of Lhe CoMMnISSiLFrDoI4MaU File 5.40MIumo CooM negoo* ;
Questions and Responses Concerning FSAR Update RuleA. REGULATORY/LEGAL1. Question: Is the updated FSAR part of the licensed basis of theplant? That is, can the original FSAR, as amended, be set aside andforgotten or is the license still based upon it? E.g., for report-ing to NRC of deviations from conditions stated in the "FSAR," whichone applies.Response: The original FSAR, as amended, is still considered to bethe licensing basis for the plant. However, as indicated in the rule,the updated FSAR "shall contain all the changes necessary to reflectinformation 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 presentschanges 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 intendsto use the updated FSAR in the future for appropriate applicationssuch as reporting of deviations from conditions stated in the "FSAR."If, as a result of possible audits, the NRC finds that the updatedFSAR is not as certified to by the licensee, appropriate enforcementaction would be take . 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 bereferred to.as the updated FSAR, will provide the most convenient reference.3. Question: Who receives update? E.g., do parties to the originalproceeding, libraries, etc., receive a copy?Response: As indicated in the rule, the licensee is only requiredto send the updated FSAR to the NRC. There is no intention to sendcopies to parties to the original proceeding. ufiless such copies arerequested in accordance with Commission regulations. It is planned to placecopies Of.the updated FSAR in the local public document room, the publicdocument room in Washington,. D. C. the Technical Information Centerand the Nuclear Safety Information Center.4. Question: In the future can the FSAR be used as the technicalspecification basis?Response: The bases for the technical specifications are includedalong with the technical specifications. If the technical specifi-cations have referenced the FSAR, they may continue to reference theupdated FSAR.5. Question: If environmental information (Chapter 2) has changed, isthe ER or EIS affected in any way?Response: The rule applies only to the FSAR. The rule imposes norequirement to revise or update the Environmental Report or Environ-mental Impact Statement. If a change was required, it would be asa result of other regulation . Question: Relative to the frequency of the updating, what do thewords 'no less frequently than annually" mean? .Response: The time interval between submittals should not exceed12 months. -B. FORMAT1. Question: For multiple unit stations with multiple FSARs:-Can they be combined into one FSAR, possible with coloredpages?-Must the format for each FSAR be the same?Response: To the extent that the plants on a multi-unit site aresimilar and have a good deal of identical information in theirFSARs, the FSARs can be combined into a single updated FSAR, forconvenience, with differences appropriately identified.The formats for each updated FSAR do not have to be the same. Asindicated in the supplementary information, the format to be usedis the option of the licensee.2. Question: Do original questions and responses have to be maintainedin 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 intothe "body" of thp updated FSAR. No separate section is require . Question: Is the initial submittal of the updated FSAR treated asa revision of the original and numbered sequentially following thelast revision or amendment?Response The initial submittal of the updated FSAR should betreated as i unique document and called the updated FSAR and not asa sequential revision of the original FSAR. Subsequent changesshould 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 theinitial update or Is it a "clean" document?Response: The initial updated FSAR should be a "clean" documentwithout change bars and revision numbers. The subsequent annualrevisions would then include the change indicators and page changeidentification.S. Question: Can the initial updated FSAR be a complete, new, FSARwithout retaining the old pages?Response: The initial updated FSAR may be a completely new documentwithout any of the original pages.C. CONTENT1. 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 update . Question: Can one eliminate information no longer applicable to anoperating plant -e.g., initial training program, start-up testprogram, etc., assuming it is in the original FSAR? (Also construc-tion QA program)Response: Information pertaining to programs described in theoriginal FSAR with amendments, such as the initial training programand the preoperational test program, should be submitted as part ofthe initial updated FSAR for completeness. The intent here is tolocate previously submitted information in one document. Submissionof 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 includeall material submitted to the NRC. Only an administrative update isrequired. 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 treatedseparately?Response; the updated FSAR should reference the Security and Emer-gency Plans that are currently in effec II5. Question: Assuming portions of the plant or systems have been modi-fled and designed to codes then currently in effect, how is thisaddressea 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 ofthe plant, it should be so indicated.6. Question: Assuming the original FSAR contains references that areno longer in.use or acceptable in industry, must they be changed andthe affected analysis revised accordingly? (For exa"ple, referenceto 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 otherConsiderations require such revision.'6