Proposed Final Regulatory Guide 1.181, "Content of the Updated Final Safety Analysis Report in Accordance with 10 Cfr 50.71(e)" - July 21, 1999

July 21, 1999

The Honorable Greta Joy Dicus
Chairman
U.S. Nuclear Regulatory Commission
Washington, DC 20555

Dear Chairman Dicus:

SUBJECT: PROPOSED FINAL REGULATORY GUIDE 1.181, "CONTENT OF THE UPDATED FINAL SAFETY ANALYSIS REPORT IN ACCORDANCE WITH 10 CFR 50.71(e)"

During the 464th meeting of the Advisory Committee on Reactor Safeguards, July 14-16, 1999, we reviewed the proposed final Regulatory Guide 1.181, which endorses NEI 98-03, Revision 1, "Guidelines for Updating Final Safety Analysis Reports," without exception. During this review, we had the benefit of discussions with representatives of the NRC staff and the Nuclear Energy Institute (NEI). We also had the benefit of the documents referenced.

Recommendation

We recommend approval of proposed final Regulatory Guide 1.181 for use by the industry.

Discussion

As a result of industry experience and other initiatives related to updated Final Safety Analysis Reports (FSARs), the NRC has determined that additional guidance regarding compliance with 10 CFR 50.71(e) is necessary. This regulation requires licensees to periodically update their FSARs. Revisions must be filed either annually or 6 months following each refueling outage, provided that the interval between successive updates does not exceed 24 months.

Although 10 CFR 50.71(e) specifies the type of new information that must be evaluated to determine if the FSAR must be updated, experience has shown that additional guidance is necessary. The staff has worked with NEI and other stakeholders to develop this additional guidance. We believe that the guidance resulting from this joint effort, which is documented in NEI 98-03, Revision 1, is sufficient for licensees to demonstrate compliance with the requirements of 10 CFR 50.71(e).

The Commission is now encouraging an evolution in the regulations that will lead to changes in the assessment of safety system performance and the types of accidents that are considered. The information in the FSAR (e.g., which describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components) must reflect these changes. As part of its efforts to develop risk-informed regulation, the staff should anticipate how the safety analysis report will evolve. It may be necessary, for example, to include in the safety analysis report information crucial to the conduct of probabilistic risk assessments.

Sincerely,

/s/

Dana A. Powers
Chairman

References:

1. Memorandum dated June 10, 1999, from David B. Matthews, Office of Nuclear Reactor Regulation, to Robert L. Seale, Chairman, ACRS, Subject: Request for Review and Endorsement of Regulatory Guide 1.181, "Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e)."

2. 10 CFR 50.71, Maintenance of Records, Making of Reports.

3. 10 CFR 50.34(e), Final Safety Analysis Report.

4. Nuclear Energy Institute, NEI 98-03, Revision 1, "Guidelines for Updating Final Safety Analysis Reports," June 1999.

5. Memorandum dated February 16, 1999, from Annette Vietti-Cook, Secretary of the Commission, to William D. Travers, Executive Director for Operations, NRC, Subject: Staff Requirements - SECY-99-001 - Proposed Guidance for Updated Final Safety Analysis Reports in Accordance with 10 CFR 50.71(e).

6. Memorandum dated June 30, 1998, from John C. Hoyle, Secretary of the Commission, to L. Joseph Callan, Executive Director for Operations, NRC, Subject: Staff Requirements - SECY-98-087 - Proposed Generic Letter 98-XX: Interim Guidance for Updated Final Safety Analysis Reports in Accordance with 10 CFR 50.71(e).