ML18106A976

Requests Exemption from Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR for Sgs,Units 1 & 2

ML18106A976
Person / Time
Site:	Salem
Issue date:	12/02/1998
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LR-N980559, NUDOCS 9812090065
Download: ML18106A976 (3)

Text

Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas ComiJ~C i*~: l§~S6, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations LR-N980559 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR EXEMPTION FROM 10CFR50.71(e)(4)

SCHEDULE REQUIREMENTS FOR FINAL SAFETY ANALYSIS REPORT UPDATES SALEM GENERATING STATION UNlTS 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 Gentlemen:

Pursuant to 10CFR50.12(a), Public Service Electric and Gas (PSE&G) requests an exemption from the requirements of 10CFR50.71 (e)(4) regarding submission of revisions to the Updated Final Safety Analysis Report (UFSAR) for Salem Generating Station Units 1 and 2. Specifically, PSE&G requests exemption from the requirements of 10CFR50.71 (e)(4) which states that "Subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months".

10CFR50.12 states that the Commission may grant exemptions from the requirements of the regulations when special circumstances exist. 10CFR50.12 further states that special circumstances exist whenever "Application of the regulation in the particular circumstance would not serve the underlying purpose of the rule."

The intent of the rule change published in the Federal Register on August 31, 1992 (57FR39358), was to provide a reduction of regulatory burden by reducing the frequency of required UFSAR updates. This burden reduction can only be achieved by single-unit facilities or multiple-unit facilities that maintain separate UFSARs. As written, the rule increases the frequency of required updates for multi-unit sites with a common UFSAR. This is contrary to the intent of the rule. For those facilities with a common UFSAR for a multiple unit site, as is the case at Salem Generating Station, the \).1:(

literal interpretation of this rule would require revision of the common Salem UFSAR within 6 months after each unit's refueling outag.e.

9812090065.981202 PDR ADOCK 05000272 p PDR

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• • DEC 2 ~-1998 Document .Control Desk I

LR-N980559 In the Summary and Analysis of Public Comments accompanying the 10CFR50.71(e)(4) rule change (57FR39355), the Nuclear Regulatory Commission (NRC) indicated that the final rule did not address multiple-unit facilities sharing a common UFSAR. However, one comment on the rule change suggested that a licensee of a multiple-unit facility should designate the refueling schedule of one of the units to establish the schedule for revision of the common UFSAR. In response to that comment the NRC stated that for "multiple facilities sharing a common UFSAR, licensees will have maximum flexibility for scheduling updates on a case-by-case basis."

Salem Units 1 and 2 have a common UFSAR and have staggered Spring/Fall refueling outages. Based upon the literal interpretation of the rule as written, PSE&G would be required to submit a UFSAR update within 6 months after each refueling outage, resulting in UFSAR updates more frequently than every 12 months. Therefore, in accordance with 10CFR50.12(a)(ii), PSE&G requests an exemption from the requirements of 10CFR50.71 (e)(4).

The requested exemption would allow PSE&G to submit the periodic updates of the common UFSAR for Salem Units 1 and 2 within 6 months after Salem Unit 1 refueling outages, but not to exceed 24 months from the last revision. The requirement that an update be submitted within 6 months after each refueling outage would not be retained.

The requested exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and safety and security.

Should you have any questions please do not hesitate to contact us.

Sincerely, 95-4933

.J .j* I *...It L* DEC 2 ""** 1998 Document Control Desk

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LR-N980559 C Mr. H. J. Miller, Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. P. Milano, Licensing Project Manager - Salem U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris (X24)

USN RC Senior Resident. Inspector - Salem Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway P.O. Box415 Trenton, NJ 08625 95-4933