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'82 DEC 10 A11:44ou.< .......m . .. . . ...

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N . 1,yfC i ember 7, 1982

Secretary of the Co:=aissionU.S. Nuclear Regulatory Commission g gggh .; gWashington, D.C. 20555 * * * * * _ - ,

moi 1'Attention: Docketing and Service Branch

KMLNRC 82-254Re: Proposed Guidance for Implementation of Standard

Review Plan Rule; Request for Comments

Dear Sir:

On October 22, 1982, the Nuclear Regulatory Commission (Commission) pub-lished in the Federal Register a notice of proposed guidance, 47 Fed.Reg. 47019. The notice presents the Co:=nission Staff's recommended" Guidance for Implementation of lOCFR50.34 (g)" (NUREG-0906) and invitescor.ments, suggestions, or recommendations on the content of the proposedguidance. Kansas Gas and Electric Company is pleased to submit the -

following corrent.

KG&E is concerned that the "Conformance with the Standard Review Plan(SRP)" rule might be expanded to include plants docketed prior toMay 17, 1982 in their FSAR updates required by 10CFR50.71(e) . To includethe evaluation required by the SFS rule in the FSAR updates would be a:.ajor, ' time-consuming undertaking providing minimal, if any, benefits.The re fore , the " Guidance for Implementation of Standard Review Plan Rule"should be written to explicitly exclude FSAR updates by plants docketedprior to May 17, 1982. *

Yours very truly,

.

8212200036 821210PDR PR50 47FR47019 PDR

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Ackncvdedged by card.N [.d '. O "

d2f b201 N. Market ~ Wichita, Kansas - Mail Address: PO. Box 208 I Wictuta. Kansas 67201 - Telephone: Area Code (316) 2616451

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"Washington Public Power Supply 8y' stem

P.O. Box 968 3000GeorgeWashingtonWay Richland Washington 99352 (509)372-5000

'82 DEC 10 NOM 2

m . t w o .v.

$' ;,;_$dA SEHV rl-

Decenber 8,1982 EfMCHk

zcm wteerrn Sdn-esomsto aunSecretary of the Comission ^

U. S. Nuclear Regulatory Comission 47 FR 4-7D/9Washington, D. C. 20555

Attention: Docketing and Service Branch

Subject:PROPOSED GUIDANCE FOR IMPLEMENTATION OFSTANDARD REVIEW PLAN

In the October 22, 1982, edition of the Federal Register (47FR47019),the NRC published a request for coments on its proposed guidance forthe implementation of the Standard Review Plan (SRP) rule. In general,the Supply System is concerned that the delay in issuance of " guidance"for a rule published seven months earlier may present an untenableposition for those applicants having their documentation efforts wellunderway or completed. Thus, we strongly recomend that NUREG-0906explicitly state it is offered for guidance only and that any systemthat documents the evaluation required by 10CFR50.34(g)(2) is acceptable.Accordingly, all statements of how an applicant "should" perform thevarious elements of the documentation process must also be softened.

'

Specific coments concerning the proposed guidance for implementation ofthe SRP are provided in the attached.

Very truly yours, . ."

,6 n dz|'

.

G. D. Bouchey, ManagerNuclear Safety & Regulatory Programs

'

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SPECIFIC SUPPLY SYSTEM COMMENTS ON NUREG-0906

,

1. The location of the documentation within the SAR should be lef t to ,

the applicant; i.e., Section 1.8 can be suggested, but it should bestated that the applicant may find a better location, particularlyif the SAR is already in preparation or canpleted.

.

2. The applicant should not be required to delete Section 1.8 on !

compliance to the Regulatoty Guides and in its place incorporatethis informatiori into the SRP review. This is an unnecessaryburden for an SAR in preparation or already written. Also, it coesnot necessarily offer the most efficient method of documentingRegulatory Guide compliance. The staff's scheme results in theburial cf Regulatory Guide compliance within and throughout the SRPreview. t

,

3. The applicant should be allowed the option to discuss exceptions tothe SRP Acceptance Criteria within the SRP review section ratherthan be required to revise sections throughout the SAR as suggestedby the examples in the notice.

4. The applicant should not be required to create new SAR sectionswhich appear in the SRP's but not in Regulatory Guide 1.70 (e.g.,Sections 5.4.12, 6.2.7 and 9.1.5). It should be acceptable if therequired information is presented somewhere in the SAR and adequatelyreferenced.

i

5. SRP Chapter 18 contains no Acceptance Criteria and, as such, an [applicant has no obligation to document this section in the review. L

,

t

6. The format indicated by Table 1.8.1 of the draft NUREG will provide ;'

for a concise documentation of the differences from the SRP, but it :

has two disadvantages in that it does not document where and how :

compliance is achieved (a task which must be performed to determinedifferences) and secondly, it focuses on the negative.

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'82 DEC 10 All:44.u ~< ....,,,

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'EI hbkC ember 7, 1982f

Secretary of the Co::nissionU.S. Nuclear Regulatory Commission ggh ^]Washington, D.C. 20555 g nu ~

Attention: Docketing and Service Branch

KMLNRC 82-254Re: Proposed Guidance for Implementation of Standard

Feriew Plan Rule; Request for Comments

Dear Sir:

On October 22, 1982, the Nuclear Regulatory Commission (Commission) pub-lished in the Federal Register a notice of proposed guidance, 47 Fed.Reg. 47019. ~he notice presents the Commission Staff's recommended" Guidance fer Implementation of 10CFR50. 34 (g)" (NUREG-0906) and invitesco=ments, suggestions, or recommendations on the content of the proposedguidance. Kansas Gas and Electric Company is pleased to submit the -

following co= cent.4

KG&E is concerned that the "Conformance with the Standard Review Plan(SRP)" rule might be expanded to include plants docketed prior toMay 17, 1982 in their FSAR updates required by 10CFR50.71(e). To includethe evaluation required my the SRP rule in the FSAR updates would be amajor, ' time-censuming undertaking providing minimal, if any, benefits.There fore , tne " Guidance for Implementation of Standard Review Plan Rule"should be written to explicitly exclude FSAR updates by plants docketedprior to May 17, 1982. '

Yours very truly,

8212200036 821210PDR PR50 47FR47019 PDR

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"Acunomieei;ee by card 9 if G Yadd '. vo #

d27 b201 N. Market - Wochsta, Kansa - Mail Address: PO. Box 208 I Woctuta, Kansas 67201 - Telephone: Area Code (316) 2616451

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Washington Public Power Supply $y'sYemP.O. Box 968 3000GeorgeWashington Way Richland. Washington 99352 (509)372-5000

'82 DEC 10 NO%2

-wu?f g N i SE A*Mv

December 8, 1982 q'uCH~ g

ZCXU fftII.M ',5 0esosaseo suu mSecretary of the Comission

U. S. Nuclear Regulatory Comission /%7 FR 47DIT(,Washington, D. C. 20555

Attention: Docketing and Service Branch

Subj ect:PROPOSED GUIDANCE FOR IMPLEMENTATION OFSTANDARD REVIEW PLA'l

In the October 22, 1982, edition of the Federal Register (47FR47019),the NRC published a request for coments on its proposed guidance forthe implementation of the Standard Review Plan (SRP) rule. In general,the Supply System is concerned that the delay in issuance of " guidance"for a rule published seven months earlier may present an untenableposition for those applicants having their documentation efforts wellunderway or completed. Thus, we strongly recommend that NUREG-0906explicitly state it is offered for guidance only and that any systemthat documents the evaluation required by 10CFR50.34(g)(2) is acceptable.Accordingly, all statements of how an applicant "should" perfonn thevarious elements of the documentation process must also be softened.

Specific coments concerning the proposed guidance for implementation ofthe SRP are provided in the attached.

Very truly yours, .;

hDQW r -

G. D. Bouchey, ManagerNuclear Safety & Regulatory Programs

,

KAH/sm

Attachment ,

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SPECIFIC SUPPLY SYSTEM COMMENTS ON NUREG-0906

1. The location of the documentation within the SAR should be left tothe applicant; i.e., Section 1.8 can be suggested, but it should bestated that the applicant may find a better location, particularlyif the SAR is already in preparation or completed.

2. The applicant should not be required to delete Section 1.8 oncompliance to the Regulatoty Guides and in its place incorporatethis information into the SRP review. This is an unnecessaryburden for an SAR in preparation or already written. Also, it doesnot necessarily offer the most efficient method of documentingRegulatory Guide compliance. The staff's scheme results in theburial of Regulatory Guide compliance within and throughout the SRPreview.

3. The applicant should be allowed the option to discuss exceptions tothe SRP Acceptance Criteria within the SRP review section ratherthan be required to revise sections throughout the SAR as suggestedby the examples in the notice.

4. The applicant should not be required to create new SAR sectionswhich appear in the SRP's but not in Regulatory Guide 1.70 (e.g.,Sections 5.4.12, 6.2.7 and 9.1.5). It should be acceptable if therequired information is presented somewhere in the SAR and adequatelyreferenced.

5. SRP Chapter 18 contains no Acceptance Criteria and, as such, anapplicant has no obligation to document this section in the review.

6. The format indicated by Table 1.8.1 of the draf t NUREG will provide '

for a concise documentation of the differences from the SRP, but ithas two disadvantages in that it does not document where and howcompliance is achieved (a task which must be performed to determinedifferences) and secondly, it focuses on the negative.

- _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .