ML17191B410
| ML17191B410 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, LaSalle  |
| Issue date: | 07/27/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17191B409 | List: |
| References | |
| NUDOCS 9908030138 | |
| Download: ML17191B410 (2) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20S55--0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO EXEMPTIONS FROM REQUIREMENTS OF 10 CFR 50.71(e)(4}
- UPDATED FINAL SAFETY ANALYSIS REPORT COMMONWEAL TH EDISON COMPANY BRAIDWOOD STATION. UNITS 1 AND 2 BYRON STATION. UNITS 1AND2 DRESDEN NUCLEAR POWER STATION. UNITS 2 AND 3 LASALLE COUNTY STATION. UNITS 1AND2
_QUAD CITIES NUCLEAR POWER STATION. UNITS 1AND2 DOCKET NOS. STN 50-456. STN 50-457. STN 50-454. STN 50-455.
50-237. 50-249. 50-373, 50-374. 50-254 AND 50-265
1.0 INTRODUCTION
By letter dated May 4, 1993, Commonwealth Edison Company (ComEd, the licensee)
_ submitted a letter to the NRC requesting that the Commission review its proposed Updated Final Safety Analysis Report (UFSAR) revision S!Jb_mitt~I po.licy,and provide-.a written response.
ComEdhad*revised its policy b'ased ori *a rule change to 10 CFR 50.71, "Maintenance of records, making of reports" that became effective October 1, 1992. The rule change_ revised the requirement to provide r~visions to the UFSAR on an annual basis. Specifically, the revised rule states, in part, that "[s)ubsequent revisions [to the Final Safety. Analysis Report (FSAR)] must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months." Because ComEd stations share common*updated FSARs, this rule would require the licensee to update each shared UFSAR annually* or within 6 months after each unit's refueling outage.
2.0 EVALUATION The requirement of 10 CFR 50.71(e)(4) ensures that all licensees update their FSARs annually or at least every refueling outage and rio less frequently than every 2 years. The current rule, as revised August 31, 1992 (57 FR 39355), was intended to provide some reduction in regulatory burden by limiting the frequency of required updates. The underlying purpose of the rule was to relieve licensees of the burden of filing annual FSAR revisions while assuring that such revisions are made at least every 24 month~. The Commission reduced the burden, in part, by permitting a licensee to submit its FSAR *revisions 6 months after refueling outages for
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ENCLOSURE 6
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- its facility. The burden reduction, however, can only be realized by single-unit facilities or multiple-unit facilities that maintain separate FSARs for each unit. The Commission did not provide in the rule for multiple unit facilities sharing a common FSAR. Rather, the Commission stated that "[w]ith respect to [the] concern about multiple facilities sharing a common FSAR,
. licensees will have maximum flexibility for scheduling updates on a case-by-case basis."
When two units share a common FSAR, the rule has the effect of requiring the licensee to update the FSAR at least annually. Because the ComEd units, which share commons FSARs, are on 18-month fuel cycles ~md have staggered refueling outages, the FSAR updates would be submitted at lea$t annually.
The staff had previously responded to ComEd's request of May 4, 1993, by letter dated June 15, 1993. In its response, the staff stated that the proposed UFSAR revision frequency meets the intent of the rule and, therefore, is acceptable. Our response was based on the Statements of Consideration associated with this rule which says that "[w]ith respect to the...
cor:icern about multiple facilities sharing a common FSAR, licensees will have maximum
- flexibility for scheduling updates on a case-by-case basis. This final rule does not address multiple facilities." Despite this cited material, the wording of 10 CFR 50.71(e)(4) is legally binding as far as the frequency of a UFSAR revision submission is concerned. Therefore, an exemption from the regulation is required to implement the revision submittal policy proposed by ComEd.
The licensee's proposed schedule for submittal of UFSAR revisions is within 24 calendar months of the previous UFSAR revision. The revision will reflect all changes for both units for the stations with FSA Rs shared by both units up to a maximum of 6 months prior to the date of filing. For the Braidwood and Byron Stations, which share a single combined FSAR, the revision will reflect all changes for ~II four units, up to a maximum of 6 months prior to the date of filing. Thus, the requirement that an update be submitted annually or within 6 months of an outage of any unit would no *1onger be retained.. With the exemption, the Braidwood/Byron, Dresden, LaSalle, and Quad Cities UFSARs will be*-updated and maintained current within 24 months of the last revision. Revising the UFSAR annually or 6 months after refueling outages for each unit is not necessary to achieve the underlying purpose of the rule.
3.0 CONCLUSION
The staff finds that the alternative proposed by the licensee is acceptable in that revising the UFSAR annually or 6 months after refueling outages for ea.ch unit is not necessary to achieve the underlying purpose of the rule (10 CFR 50.71 (e)(4)), which is to require the FSAR of each station be revised at least once per 24 months.
Principal Contributor: D. Skay Date: July 27, 1999