ML20135C367
| ML20135C367 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Catawba, McGuire  |
| Issue date: | 02/24/1997 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9703030533 | |
| Download: ML20135C367 (4) | |
Text
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ll-l DukeIbwerCompany M S Toacw
. P.O. Box 1006 Senior ViceItesident Charlotte,NC2820H006 Nuclear Generation (704)382-2200 Ollice (704)3824360 Fax DUKEPOWER February 24, 1997 U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555-0001
Subject:
McGuire Nuclear Station Docket Nos. 50-369, 50-370 Catawba Nuclear Station Docket Nos. 50-413, 50-414 Request for Exemption per 10 CFR 50.12 Regulatory Burden Reduction from 50.71(e)
Pursuant to 10_ CER 50.12 (a), Duke Power requests exemption from the requirements of 10 CFR 50.71(e) (4) regarding submission of a
revisions to the Updated Final Safety Analysis Reports (UFSARs) for the McGuire and Catawba nuclear plants.
Due to the literal language of 10 CFR 50.71(e) and as allowed by 10 CFR 50.12, Duke Power Company hereby requests an exemption from the requirements of 10 CPR 50.71(e) (4), in order to allow McGuire and Catawba to update the single, unified UFSAR for each of its two-unit sites six months after each respective Unit 2 refueling outage.
The enclosure to this letter more fully describes the background and the justification for seeking this exemption.
Questions may be directed to Laura T. Burba at (704) 382-3171.
Sincerely, N
b.
M.S. Tuckman I
Ol
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Enclosure:
9703030533 970224 PDR ADOCK 05000369%
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February 24, 1997 Document Control Desk i
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xc:
Samuel J. Collins, Director l
Office of Nuclear Reactor Regulation i
Peter Tam, Project Manager ONRR, Nuclear Regulatory Commission L
Victor Nerses, Senior Project Manager, ONRR, Nuclear Regulatory Commission l
Luis A. Reyes Regional Administrator, Region II l
R.
J.
Freudenberger NRC Resident Inspector, CNS i
S. M. Shaeffer NRC Resident Inspector, MNS l
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Background and Justification Duke Power hereby requests an exemption for McGuire and Catawba from the reporting frequency stated in 10 CFR 50.71(e) which requires that UFSAR revisions be filed annually or 6 months after each refueling outage, not to exceed 24 months. This optional reporting frequency based on refueling outages was published in the Federal Register August 22, 1992(57 FR 399353) and became effective October 1, 1992.
According to the Summary and Analysis contained in the Federal Register Notice accompanying the revised rule, "in the case of multiple facilities sharing a common UFSAR, licensees will have maximum flexibility for scheduling updates on a case-by-case basis". Duke Power has interpreted this reporting requirement, according to its most logical application and stated intent, that being the reduction of regulatory burden.
Where there is one shared, common UFSAR for a multiple unit site, as in the case of either McGuire or Catawba, literal application of this rule would require the successive revision of the same document within 6 months af ter each unit's refueling outage.
Duke therefore requests approval to submit revisions to McGuire j
and Catawba's UFSARs to the NRC within 6 months of the end of each respective Unit 2 refueling outage, at an interval not to exceed 24 months.
Please note that the intent has never been to exceed the 24 month interval between sucessive revd ions.
If this exemption is granted, Duke plans to submit
_Ut Levisions for McGuire and Catawba on the following basis:
i McGuire Unit 1 & 2 UFSAR Six months after each Unit 2 refueling outage not to exceed 24 months between successive revisions.
Catawba Unit 1 & 2 UFSAR Six months after each Unit 2 refueling outage not to exceed 24 months between successive revisions.
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10 CPR 50.12 authorizes the Commission, upon application by any interested person, to grant exemptions from the requirements of the regulations when special circumstances are present.
Section j
(ii) of CFR 50.12(a) states "special circumstances are present whenever... application of the regulation in the particular i
circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule."
Duke Power believes that such special circumstances are present in this instance and that exemption from the regulatory i
requirements of 50.71(e) is consequently warranted, in that literal compliance, in the case of any plant site with one common UFSAR shared by multiple units, would result in an undue regulatory burden.
Literal compliance with the rule would more than double the resources now required to electronically ir-3rporate the changes and republish each of these large documents (each totaling more than 3,000 pages)and transmit the revision packages to the NRC and other manual holders.
This exemption is authorized by law, will not present an undue risk to the public health and safety and is consistent with common defense and security and is otherwise in the public interest.
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