ML20095K081

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Safety Evaluation Accepting Licensee 950609 Request for Exemption from Requirements of 10CFR50.71(e)(4)
ML20095K081
Person / Time
Site: Brunswick  
Issue date: 12/21/1995
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20095K074 List:
References
NUDOCS 9512280085
Download: ML20095K081 (2)


Text

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. e UNITED STATES g

NUCLEAR REGULATORY COMMISSION W

WASHINGTON, D.C. 3000HOO1 ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EXEMPTION FROM FINAL SAFETY ANALYSIS REPORT UPDATE REQUIREMENTS OF 10 CFR 50.71(e)(4)

CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 i

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1.0 INTRODUCTION

By letter dated June 9, 1995, Carolina Power & Light Company (the licensee) submitted a request for an exemption from the requirements of 10 CFR 50.71(e)(4), " Maintenance of records, making reports."

10 CFR 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 Brunswick Steam Electric Plant (BSEP) 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.

2.0 EVALUATION 10 CFR 50.71(e)(4) ensures that all licensees update their FSARs at least

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every refueling outage and no less frequently than every two 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; this is contrary to the intent i

of the rule. A recent revision to 10 CFR 50.71(e) was intended to provide some reduction in regulatory burden by limiting the frequency of required updales. The burden reductions provided in the revised regulation, however, can only.be realized by single unit facilities or multiple unit f acilities

,that maintain separate ESARs for each unit.

For multiple unit facilities with a common updated FSAR, the "each refueling outage" requirement increases rather than decreases the regulatory burden. The authors of the revised rule recognized this concern for multiple unit plants by stating in response to a comment 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.

This final rule does not address multiple facilities."

57 FR 39353 (August 31,1992).

The requested exemption would require periodic updates once per fuel cycle, based on the BSEP Unit I refueling outage schedule, but not to exceed 24 months from the last 9512280085 951221 PDR ADOCK 05000324-P PDR a

. submittal. The requirement that an update be submitted within six months of an outage of each unit is not retained. Allowing the exemption would maintain the BSEP FSAR current within 24 months of the last revision and would not exceed a 24-month interval for submission of the 10 CFR 50.59 design change report for either unit.

3.0 CONCLUSION

The staff finds that the proposed alternative prnvides an equivalent level of protection as the existing regulations; therefore, the proposed exemption from 1

10 CFR 50.71(e)(4) for BSEP Units 1 and 2 is acceptable.

Principal Contributors:

E. Fuentes G. Wunder Dated:

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