ML20057G046

Requests for Exemption from Requirements Re Submittal of USAR Per 10CFR50.12

ML20057G046
Person / Time
Site:	Comanche Peak
Issue date:	10/14/1993
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-93356, NUDOCS 9310200122
Download: ML20057G046 (2)

Text

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.Ref. # 10CFR50.71(e)'

10CFR50.12 Tl/ ELECTRIC -

October 14, 1993 1

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-U..S; Nuclear. Reg.' cory Commission l

' Attn:- Document; Control Room

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i Washington,- DC: 20555 :

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND'50-446 i

~REQUESTHFOR EXEMPTION FROM REQUIREMENTS RELATED T0 l

o THEKSUBMITTAL OF THE UPDATED SAFETY ANALYSIS REPORT l

REF:

NRC? letter from' George.F. Dick, Jr., to William J. Cahill, Jr.,

j dated' July 15, 1991:

Gentlemen::

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T10CFR50.71('e)(3)(i): requires that within two years of the granting of an j

~. operating license, a licensee _ submit an updated Final Safety Analysis Report l

1(FSAR). 'The regulation defines the updated-FSAR as."a revision of the 3

' original FSAR containing those original-pages.that are still applicable plus j

inew-replacement pages'.'. lTU Electric requests an. exemption to the l requirement to. resubmit those'originalLpages which are still applicable.

h The-requested exemption is. authorized by 10CFR50.12, which provides that

exemptions-may be granted when application'of a regulation in the particular l

E circumstances would'not serve the underlying purpose of the rule or is not i

necessary to achieve the underlying purpose of.the rule i

f(10CFR50.12(a)(2)(ii))..The-purpose of the 10CFR50.71(e) rule is to ensure thatLthe NRC can maintain accurate descriptions'of the licensing basis of x

Leach licensed plant. Prior-to the implementation of this rule, the FSAR was fprimarily used as a means of describing a plant's licensing basis for the

purpose of obtaining an. operating license. -Upon-issuance of the operating

' license Ethe licensee was:1not required to maintain the FSAR current. Thus, Lfor.many plants, the FSAR became a: historical document'and was often

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[significantly out-of date. Upon the issuance of the rule the FSAR was required to become a living document, to be maintained current for the life'

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of

the. plant.

The provision of the update rule which requires the re-Ti'ssuance.of allLapplicabl.e original pages_(as well as updated replacement

.pages), was intended;to ensure that.the NRC' copies of the FSARs~are complete

.L Jas-well as accurate.:

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Comanche Peak was licensed well af ter the issuance of the FSAR update rule.

From the time of the original FSAR submittal in February,1978, until the current amendment, there has never been a significant period during which the FSAR has not been kept current.

In those 15 years, 90 updates (original and 89 amendments) have been issued. The average time between amendments has been less than 3 months. Following the licensing of CPSES Unit 1 in February of 1990, TU Electric decided to perform the 10CFR50.71(e) update i

incrementally as part of regularly scheduled FSAR amendments.

Aside from the normal FSAR revisions due to plant changes, the update process consisted primarily of incorporating responses to NRC questions (Q&Rs) into the FSAR

' text.

Since Unit 1 licensing, 11 amendments have been issued, all of which have included Q&R incorporations.

TV Electric believes that the frequent.

updates have resulted in an FSAR which has been maintained exceptionally accurate.

Based on telephone conversations with the NRC staff, TU Electric believes that the NRC copies of the CPSES FSAR are complete and current.

Thus the re-issuance of original pages is unnecessary to achieve the underlying purpose of the rule.

TU Electric does not maintain additional complete and current FSARs in stock. Therefore, if the exemption is not granted, TU Electric would be required to reprint the entire (updated) FSAR.

The current FSAR contains approximately 7,500 to 8,000 pages of text and tables and 1,500 to 2,000 I

sheets of figures,.the vast majority of which do not require revision.

The reprinting process would require significant administrative and financial resources but would not produce a commensurate level of benefit.

TU Electric therefore proposes to continue updating the FSAR using the current amendment process.

The last amendment in that process, containing only replacement pages, would convert the FSAR to the updated FSAR.

Based on the referenced NRC letter which granted a schedular exemption for a Unit 1 updated FSAR, the amendment which converts the FSAR to a combined Unit 1 and 2 updated FSAR, will be submitted by February 2, 1995.

Should you have any questions concerning this request, please contact Bob Dacko at (214) 812-8228.

Sincerely, William J.

ahill, Jr.

BSD c-Mr. J. L. Milhoan, Region IV Resident Inspectors, CPSES (2)

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~Mr. T. A. Bergman, NRR