Home > Electronic Reading Room > Document Collections > Commission Documents > Commission Papers (SECY) > 2001 > SECY-01-0055

POLICY ISSUE
(Information)

SECY-01-0055

March 28, 2001

• PURPOSE:
• BACKGROUND:
• DISCUSSION:
• CONCLUSIONS:
• COORDINATION:

PURPOSE:

To inform the Commission of the results of our assessment of the guidance for updating reactor final safety analysis reports (FSARs).

BACKGROUND:

In September 1999, the staff issued Regulatory Guide 1.181 (RG 1.181), "Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e)," to provide guidance on the content of licensees' updated FSARs. RG 1.181 endorsed a document developed by the Nuclear Energy Institute (NEI), NEI 98-03, "Guidelines for Updating Final Safety Analysis Reports," without exception as an acceptable method for compliance with 10 CFR 50.71(e). NEI 98-03 provides guidance on the level of detail needed in updated FSARs and contains provisions for removing information that is redundant, outdated, or excessively detailed. These documents were developed as part of an industry initiative to better ensure that updated FSARs correctly describe licensees' facilities.

In a staff requirements memorandum (SRM) dated September 8, 1999, the Commission asked the staff to monitor licensee FSAR updates made in accordance with RG 1.181 and NEI 98-03 and to report the findings to the Commission by March 20, 2001. The monitoring program was to assess (1) whether the guidance for FSAR updates or design bases or both needs to be modified and (2) whether additional regulatory oversight is warranted.

After receiving the SRM, the staff issued RG 1.186, "Guidance and Examples for Identifying 10 CFR 50.2 Design Bases," in December 2000, to provide a better description of the items that are included in the design bases and that should be considered during FSAR updates. RG 1.186 endorsed Appendix B of industry document NEI 97-04, "Design Bases Program Guidelines," dated July 27, 2000, without exception.

DISCUSSION:

To implement the Commission's request, the Division of Regulatory Improvement Programs (DRIP) and the Division of Licensee Project Management (DLPM) of the Office of Nuclear Reactor Regulation prepared a form to be completed by project managers during FSAR update reviews. Completed forms were transmitted to DRIP staff and evaluated on an ongoing basis. Between January 1, 2000, and March 1, 2001, DLPM project managers reviewed approximately 43 FSAR updates and DRIP staff completed the evaluation of 43 FSAR update reviews. The tabulated results of the reviews are attached.

The FSAR update reviews showed the following:

• All of the FSAR updates were submitted within 10 CFR 50.71(e) time requirements or as allowed by plant exemptions.

• In general, descriptions of changes to the facility or design bases were appropriately documented. For some changes, the staff sought additional information from the licensee, the regional office, or the resident inspector and, in some instances, this action resulted in information being added to the updated FSAR.

• About one-third of the licensees used the guidance in RG 1.181 and NEI 98-03 to remove outdated, redundant, or excessively detailed information from their FSARs. The staff did not identify significant concerns about the information removed.

• Some licensees removed detailed drawings such as piping and instrumentation drawings (P&IDs) from their FSARs in accordance with RG 1.181.

• Several licensees relocated documents from the FSAR to other licensee controlled programs in accordance with RG 1.181.

• Licensees did not remove risk-significant information from their FSARs. (A caution statement in RG 1.181 advised licensees not to remove risk significant information.)

In summary, about one-third of the licensees used the guidance in RG 1.181 and NEI 98-03 to remove redundant, outdated, or excessively detailed information from their FSARs. Changes to the facility or the plant design bases were appropriately documented and information was removed appropriately. No significant discrepancies were identified by the staff and minor discrepancies were resolved by contacting the responsible licensee. It was also noted that the explanation for FSAR changes was brief; however, the regulation does not require an explanation and a brief explanation is consistent with past practice.

CONCLUSIONS:

On the basis of staff review of FSAR updates, we conclude that the guidance for FSAR updates (RG 1.181 and NEI 98-03) and design bases (RG 1.186) is sufficient, that additional guidance is not needed, and that the current level of regulatory oversight is appropriate. Because we did not find any significant problems regarding the use of RG 1.181 and RG 1.186 in updating FSARs, we will not continue to assess their implementation. We will, however, continue to review FSAR updates in accordance with NRR procedures and address any plant-specific issues as appropriate.

COORDINATION:

The Office of General Counsel has reviewed this paper and has no legal objection.

ATTACHMENT

Tabulated Results of FSAR Update Reviews

Privacy Policy | Site Disclaimer
Thursday, February 22, 2007