ML17334B697

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Safety Evaluation Supporting Proposed Exemption to Allow Licensee to Submit FSAR Updates on Schedule Consistent w/24 Month Period Contemplated by 10CFR50.71(e)(4)
ML17334B697
Person / Time
Site: Cook  
Issue date: 03/03/1998
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML17334B696 List:
References
NUDOCS 9803060203
Download: ML17334B697 (3)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555EI001

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By letter dated August 5, 1997, the Indiana Michigan Power Company (the licensee) submitted a request for an exemption from the requirements of 10 CFR Section 50.71(e)(4), "Maintenance

, of records, making of reports." Section 50.71(e)(4) requires, in part, that "Subsequent 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 to the FSAR does not exceed 24 months." The two Donald C. Cook units share a common FSAR; therefore, this rule requires the licensee to update the same document within 6 months after a refueling outage for either unit.

2.

EMUlAJOM Section 50.71(e)(4) ensures that all licensees update their FSARs at least every refueling outage and no less frequently than every 2 years.

When two units share a common FSAR, the rule has the effect of making the licensee update the FSAR roughly every 12 to 18 months.

A recent revision to 10 CFR 50.71(e), which added the option to update the FSAR 6 months after each refueling outage provided the interval between successive updates to the FSAR does not exceed 24 months, was intended to provide some reduction in regulatory burden by limitingthe frequency of required updates.

Unfortunately, the burden reductions provided in the revised regulation can only be realized by single-unit facilities or multiple-unit facilities that maintain separate updated FSARs for each unit. For multiple-unit facilities with a common updated FSAR, the requirement pertaining to "each refueling outage" increases rather than "decreases the regulatory burden. The'authors of the revised rule recognized this concern for multiple-unit plants when the following statement was made in response to a petitioner's comment:

'Vfithrespect to petitioner's concern about multiple facilities sharing a common FSAR, licensees willhave maximum flexibilityfor scheduling updates on a case-by-case basis.

This final rule does not address multiple facilities." (57 FR 39353, August 31, 1992) 11I803060203 980303 PDR ADQCK 050003i5 p

PDR, The requested exemption would require periodic updates annually or once every fuel cycle (based on the unit with the shortest interval between scheduled refueling outages), but not to exceed 24 months from the last submittal. The requirement that the update be submitted within 6 months of each outage is not retained.

This exemption is consistent with the underlying purpose of the rute change which recognized that annual updates were not necessary and intended to reduce this burden so long as successive updates do not exceed 24-months, as indicated in 10 CFR 50.71(e)(4).

Allowingthe exemption would keep the Donald C. Cook FSAR current within 24 months of the last revision and would not exceed the 24-month interval for submission of the 10 CFR 50.59 design change report for either unit.

3.0~O The staff finds that the proposed exemption willallow the licensee to submit FSAR updates on a schedule consistent with the 24-month period contemplated by 50.71(e)(4).

Therefore, the proposed exemption from 10 CFR 50.71(e)(4) for the Donald C. Cook Nuclear Plant, Units 1 and 2, is acceptable pursuant to 10 CFR 50.12(a)(2)(ii).

Principal Contributors:

J. Hickman E. Fuentes G. Wunder Dated:

March 3, 1998

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