ML20199A040
| ML20199A040 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/19/1998 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9801270095 | |
| Download: ML20199A040 (2) | |
Text
- - _ _ _ _ _ - _ - _ _ _ _ _ - _ - - - -
Dave Mor:y
' Southern Nuclear Vice Pre %t.
. Operating Compa y
- FarleyProject P.O. Box 1295 Birmingharn. Alabama 35201 tet 205.932.5131 SOUTHERN h January ~19, 1998 COMPANY Energy to Serve Your%ld**
Docket Nos. 50-348 10 CFR 50.71(c) 50-364 U. S. Nuclear Regulatory Commisdon ATfN: Document Control Desk Washingtor., D. C, 20555 Joseph M. Farley Nuclear Plant.
Request for Exemption to 10 CFR 50.71(c)(4)
Final Safety Analysis Report Update Schedule Ladies and Gentlemen:
Pursuant to 10 CFR 50.12(a), Southem Nuclear Operating Company (SNC) hereby requests an exemption from the requirements of 10 CFR 50.71(c)(4) regarding submission of revisions to the Updated Final Safety Analysis Report (UFSAR) for the Joseph M. Farley Nuclear Plant.
Specifically, this exemption request is associated with the schedule requirements contained in 10 CFR 50.71(c)(4) which stipulates that revisions to the UFSAR must be filed annually or 6 months v.
after each refueling outage provided the interval between successive updates does not exceed 24 months. Far!cy is a two-unit plant site having a common UFSAR. 'Iherefore, given a literal interpretation of the language contained in 10 CFR 50.71(c)(4), SNC would be required to update the Farley UFSAR within 6 months after each respective unit's refueling outage.
' t.
When a two-unit plant site such as Farley shares a common UFSAR and has staggered 18 month Spring / Fall refueling outages,10 CFR 50.71(c)(4) has the net effect of potentially requiring the UFSAR to be updated more frequently than every 12 months. The rule change that was published in the Federal Register on August 31,1992 (57 FR 39358) and became effective on October 1, 1992, and remains effective today, was intended to provide some reduction in regulatory burden by 1
' limiting the frequency of required updates. However, as written, the burden reduction can only be -
realized by single-unit facilities, or multiple-unit facilities that maintain separate UFSARs for each unit, neither of which is the case for Farley. Consequently, since Farley is a multigie-unit facility
/
with a common UFSAR, the phrase "each refueling outage" in 10 CFR 50.71(c)(4) increases
(>
rather than decreases the regulatory burden, which is contrary to the intent of the rule.
Ro O in the Summary and Analysis of Public Comments accompanying the 10 CFR 50.71(c)(4) rule change (57 FR 39355), the Nuclear Regulatory Commission (NRC) indicated that the final rule did not address multiple-unit facilities sharing a common UFS AR. However, one comment 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 FSAR, licensees will have maxim 2m flexibility for scheduling updates on a case-by-case basis." Accordingly, SNC interpreted this -
I.ll.;ilil.l I.ll Ill.llll ll 9901270095 9901'a9 N- -
PDR ADOCK 05000349>
P PDR f
(
.=
.gy*
U.S. Nuclear Regulatory Comn ssion -
Page 2 reporting requirement to its most logical application and stated intent - that being to the reduction -
iof regulatory burden. %c employment of this practice has been discussed with the hRC staff and -
- is also included in docketed correspondence which contains our UFSAR revision submittal schedule. Due to recent discussions with the NRC staff, SNC now understands that a literal
~
interpretation of 10 CFR 50,71(eX4) requires a specific NRC exemption te utilize this schedule; --
although, this interpretation is in opposition to the burden-reduction premise of the rule.
The requested exemption will allow periodic updates of the Farley UFSAR once per fuel cycle,-
-.within 6 months following completion of cach Farley Unit I refueling outage, not to exceed 24 -
, months from the last submittal. Therefore, the regulatory requirement that an update be submitted within 6 months following each unit's refueling outage would not be retained. - Allowing the exemption would maintain the Farley UFSAR within 24 months of the last revision and would not exceed a 24 month interval for the submission of the 10 CFR 50.59 summary report. The proposed exemption provides an equivalent level of protection to the existing regulation and should -
be found acceptable. Because the primary intent of the rule as stated by the NRC was burden -
reduction and the current NRC rtsffinterpretation of the rule would increase the regulatory burden
- of the Faricy staff by requiring updates to the common Faricy UFSAR within 6 months after cach respective unit's refueling outage, this exemption reyiicst qualifics under 10 CFR 50.12(aX2Xii).
This exemption is allowed by law, will not present an undue risk to the public health and safety and is consistent with cammon defense and security and is otherwise in the public interest.
Sincerely, Q ') _ ]htM s
Dave Mercy DNMffMM cc:.Mr. L. A. Rcycs, Region 11 Admimstrator -
' Mr. J.-l. Zimmerman,-NRR Project Manager-Farley
--Mr. T M. Ross, Senior Resident Inspector Farley r
k s
_f-[
E y
.x 1
...,...i......,...
,g.
4,
_ _J
-