ML17265A199
| ML17265A199 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/24/1998 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9804030139 | |
| Download: ML17265A199 (14) | |
Text
~
CATEGORYL REGULATORY INFORMATION DISTRIBUTXON SYSTEM (RIDS)
ACCESSION NBR:9804030139 DOC.DATE: 98/03/24 NOTARIZED: NO DOCKET FACIL:50-244'obert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas E Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION VISSING,G.S.
SUBJECT:
Withdraws 980203 request for exemption to 10CFR50.71(e)(4) 10CFR50.71(e)
(1) requirements due unanticipated software
- conditions associated w/providing electronic browsers to NRC.
DISTRIBUTION CODE: A053D COPIES RECEIVED:LTR, I ENCL Q SIZE:
TITLE: OR Submittal-: Updated FSAR (50.71) and Amendments A.
NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72) 05000244 G
RECIPIENT ID CODE/NAME PD1-1 PD INTERNAL: AEOD/DOA/IRB RGN1 COPIES LTTR ENCL RECIPIENT XD CODE/NAME VISSING,G.
FILE CENTER 1
COPIES LTTR ENCL EXTERNAL: ZHS NRC PDR NOAC D
0 N
NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
ON EXTENSION 415-2083 4
Q TOTAL NUMBER OF COPIES REQUIRED:
LTTR 9
ENCL
A AND ROCHESIER DASAND RIECIIIICCORRDRA IION ~ 88 EASYAYENIIE,ROCHESIER, N Y IdddR II ~'REA CODE 216 Sdd 2288 RCtBcRT C. MECR=DY Y ce?res dent tNvc eor Oadot o"s March 24, 1998 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Guy S. Vissing Project Directorate I-1 Washington, DC 20555
SUBJECT:
Request for Exemption to 10CFR50.71(e)(4),
and 10CFR50.71(e)(l)
Requirements R.E.
Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Vissing:
Rochester Gas
& Electric (RG&E) herby withdraws its exemption request (Reference
- 1) of February 3,
- 1998, due to unanticipated software license conditions associated with providing electronic browsers to the NRC.
This request retains all other major points of the original request, except for the request to reduce the number of copies to be submitted.
10CFR50.71(e)(4) requires that RG&E update the Ginna Final Safety Analysis Report (FSAR) periodically and file revisions "annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months.
The purpose of this letter is to request a one-time exemption from the requirements of 10CFR50.71(e)(4) to file within 6 months of Ginna's last refueling outage and to obtain approval to submit the next FSAR update by 12/16/98, i.e., within 24 months of the last submittal.
LRG&E would include changes "up to a maximum of 6 months prior to the date of filing" (12/16/98),
as required by 10CFR50.71(e)(4).]
10CFR50.71(e)(1) requires that licensees submit revisions "on a replacement page basis...
accompanied bye a list which identifies the current pages of the FSAR following page replacement."
This letter requests an on-going exemption from the requirements of 10CFR50.71(e)(1) in that future revisions to the FSAR will be controlled on an electronic file basis; the entire file and all automatically numbered pages within the file will have the same revision number.
9804030l39 980324 PDR ADOCK 05000244 P
RG&E is working with the NRC to convert both its Technical Specifications and FSAR to Standard Generalized Markup Language (SGML) with the goals of:
~
distributing these documents to RG&E users in searchable electronic book format (including figures, equations, tables, etc.),
~
maintaining them as living documents with as close to real-time changes as possible (approximately quarterly),
and
~
distributing those changes instantly via update of the electronic files.
The conversion to SGML will save RG&E an estimated
$ 15,000 annually in printing and distribution costs and will save personnel time in searching the Ginna Station design and licensing bases during 10CFR50.59 reviews.
This will al'so facilitate our effort, as described in our February 7,
1997 50.54(f) letter, to collate and validate design basis information for selected risk significant systems and topics, electronically linked to the UFSAR.
The following dates are pertinent regarding this FSAR exemption request:
RG&E's last FSAR submittals were 7/22/96 and 12/16/96; thus, 12/16/98 is the end of the 24 month period from the date of the last FSAR submittal.
2 ~
RG&E's next FSAR update is due,5/21/98 (6 months after the last refueling outage).
10CFR50.12, "Specific Exemptions," allows the Commission to consider'ranting an exemption when special circumstances are present.
This exemption falls under the special circumstances provided for in 10CFR50.12(a)(2)(iv),
which states that an exemption may be granted if it "would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption."
The benefit to the public health and safety is that. the FSAR would become more accessible in the SGML format, encouraging better research by RG&E of the plant's licensing and design bases.
This future increased accessibility compensates for the delay in FSAR updating which will result from the granting of the exemption.
It is requested that this exemption be reviewed and approved by the NRC Staff at the earliest possible date.
Granting the exemption will minimize the cost to RG&E of refocusing its efforts on performing the update in the traditional manner.
It should be noted that:
~
There is precedence for the period of two years between FSAR submittals in that it is consistent with plants on a two year refueling cycle, and
~
RG&E will be able to include the first results from its UFSAR verification project in a delayed submittal.
(see RG&E correspondence dated 2/7/97, "Response to NRC Request for Information Pursuant to 10CFR50.54(f)
Regarding Adequacy and Availability of Design Bases Information" )
Please also note that the granting of an exemption will supersede the following two statements made by RG&E to the NRC:
~
RG&E correspondence dated 11/25/97, "60 Day Response to NRC Inspection Report No. 50-244/97-201, A/E Inspection."
This correspondence stated that RG&E would correct several discrepancies in the FSAR identified during the A/E inspection "in the next scheduled UFSAR revision to be issued on or before May 21, 1998."
~
RG&E UFSAR submittal, Revision 13, dated 12/16/96.
This correspondence stated that RG&E was modifying its annual submittal interval to 18 months and within 6 months after each refueling outage.
Please contact Mr. George Wrobel, Manager Nuclear Safety and Licensing, at (716)724-8070, if you have any questions related to this request.
Very truly yours, Robert C. Mecr dy Reference 1:
Correspondence from Robert C. Mecredy to Guy S.
Vissing,"Request for Exemption to 10CFR50.71(e)(4),
and 10CFR50.4 (b)(6) Requirements",
dated Febryary 7, 1998.
EZF4494
xc:
Mr. Guy Vissing (Mail Stop 14B2)
Project Directorate I-1 Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector
CATEGORY REGU ORY INFORMATION DISTRIB SYSTEM (RIDS)
ACCESSION NBR:9804030139 DOC.DATE: 98/03/24 NOTARIZED: NO FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
" Rochester Gas
& Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION VISSING,G.S.
DOCKET 05000244
SUBJECT:
Withdraws 980203 recpxest for exemption to 10CFR50.71(e)
(4) 10CFR50.71(e)
(1) recpxirements,due unanticipated software conditions associated w/providing electronic browsers to NRC.
DZSTRZBUTZON CODE:
A053D COPZES RECEZVED:LTR
)
ENCL Q SZEE:
TITLE: OR Submittal:
Updated FSAR (50.71) and Amendments NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72)
A T
05000244
.8 RECIPIENT ID CODE/NAME PD1-1 PD INTERNAL: AEOD/DOA/IRB RGN1 COPIES LTTR ENCL RECIPIENT ID CODE/NAME VISSING,G.
COPIES LTTR ENCL EXTERNAL: IHS NRC PDR NOAC D
0 E
N NOTE TO ALL ERIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
ON EXTENSION 415-2083 c3 TOTAL NUMBER-OF COPIES REQUIRED:
LTTR 9
ENCL
i,
~
AND ROCHESTER GASANDEIECTRIC CORPORATION ~ 89 FASTAYENUE, ROCHESTER, N. Y IrI6d9-0001 ARFA CODE716 546-2700 ROBERT C. MECREDY Vice President Nucteor Operotions March 24, 1998 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Guy S. Vissing Project Directorate I-1 Washington, DC 20555
SUBJECT:
Request for Exemption to 10CFR50.71(e)(4),
and 10CFR50.71(e)(1)
Requirements R.E.
Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Vissing:
Rochester Gas
& Electric (RG&E) herby withdraws its exemption request (Reference
- 1) of February 3,
- 1998, due to unanticipated software license conditions associated with providing electronic browsers to the NRC.
This request retains all other major points of the original request, except for the request to reduce the number of copies to be submitted.
10CFR50.71(e)(4) requires that RG&E update the Ginna Final Safety Analysis Report (FSAR) periodically and file revisions "annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months.
The purpose of this letter is to request a one-time exemption from the requirements of 10CFR50.71(e)(4) to file within 6 months of Ginna's last refueling outage and to obtain approval to submit the next FSAR update by 12/16/98, i.e., within 24 months of the last submittal.
[RG&E would include changes "up to a maximum of 6 months prior to the date of filing" (12/16/98),
as required by 10CFR50.71(e)(4).]
10CFR50.71(e)(1) requires that licensees submit revisions "on a replacement page basis...
accompanied by a list which identifies the current pages of the FSAR following page replacement."
This letter requests an on-going exemption from the requirements of 10CFR50.71(e)(1) in that future revisions to the FSAR will be controlled on an electronic file basis; the entire file and all automatically numbered pages within the file will have the same revision number.
9804030<S9
'tt8032e PDR ADOCK 05000244 P
~45
4
RG&E is working with the NRC to convert both its Technical Specifications and FSAR to Standard Generalized Markup Language (SGML) with the goals of:
~
distributing these documents to RG&E users in searchable electronic book format (including figures, equations, tables, etc.),
~
maintaining them as living documents with as close to real-time changes as possible (approximately quarterly),
and
~
distributing those changes instantly via update of the electronic files.
The conversion to SGML will save RG&E an estimated
$15,000 annually in printing and distribution costs and will save personnel time in searching the Ginna Station design and licensing bases during 10CFR50.59 reviews.
This will also facilitate our effort, as described in our February 7,
1997 50.54(f) letter, to collate and validate design basis information for selected risk significant systems and topics, electronically linked to the UFSAR.
The following dates are pertinent regarding this FSAR exemption request:
RG&E's last FSAR submittals were 7/22/96 and 12/16/96; thus, 12/16/98 is the end of the 24 month period from the date of the last FSAR submittal.
2 ~
RG&E's next FSAR update is due 5/21/98 (6 months after the last refueling outage).
10CFR50.12, "Specific Exemptions," allows the Commission to consider granting an exemption when special circumstances are present.
This exemption falls under the special circumstances provided for in 10CFR50.12(a)(2)(iv),
which states that an exemption may be granted if it "would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption."
The benefit to the public health and safety is that the FSAR would become more accessible in the SGML format, encouraging better research by RG&E of the plant's licensing and design bases.
This future increased accessibility compensates for the delay in FSAR updating which will result from the granting of the exemption.
It is requested that this exemption be reviewed and approved by the NRC Staff at the earliest possible date.
Granting the exemption will minimize the cost to RG&E of refocusing its efforts on performing the update in the traditional manner.
It should be noted that:
~
There is precedence for the period of two years between FSAR submittals in that it is consistent with plants on a two year refueling cycle, and
~
RG&E will be able to include the first results from its UFSAR verification project in a delayed submittal.
(see RG&E correspondence dated 2/7/97, "Response to NRC Request for Information Pursuant. to 10CFR50.54(f)
Regarding Adequacy and Availability of Design Bases Information" )
Please also note that the granting of an exemption will supersede the following two statements made by RG&E to the NRC:
~
RG&E correspondence dated 11/25/97, "60 Day Response to NRC Inspection Report No. 50-244/97-201, A/E Inspection."
This correspondence stated that RG&E would correct several discrepancies in the FSAR identified during the A/E inspection "in the next scheduled UFSAR revision to be issued on or before May 21( 1998."
~
RG&E UFSAR submittal, Revision 13, dated 12/16/96.
This correspondence stated that RG&E was modifying its annual submittal interval to 18 months and within 6 months after each refueling outage.
Please contact Mr. George Wrobel, Manager Nuclear Safety and Licensing, at (716)724-8070, if you have any questions related to this request.
Very t uly yours, Robert C. Mecr dy Reference 1:
Correspondence from Robert C. Mecredy to Guy S.
Vissing,"Request for Exemption to 10CFR50.71(e)(4),
and 10CFR50.4 (b)(6) Requirements",
dated Febryary 7, 1998.
EJF5494
l
xc:
Mr. Guy Vissing (Mail Stop 14B2)
Project Directorate I-1 Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector