ML20199B711
| ML20199B711 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/23/1998 |
| From: | Mccoy M SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LCV-1076, NUDOCS 9801290001 | |
| Download: ML20199B711 (2) | |
Text
I C. K. McCey Soc &ern Nnclear Vce Proudent Opersting Company. lac.
Vogtle Project 40 invemon Center Parkway P0 tot 1795 B:tmingham, Alabama 35201 Tot 205 992.7122 Iex 205 992bt03 SOUTHERN h COMPANY January 23, 1993 Em rp ro Sem Yarhld' Docket Nos. 50-424 LCV-1076 50-425 U. S Nuclear Regulatory Commission ATrN: Document Control Desk Washington, D. C= 20555 VOGTLE ELECTRIC GENERATING PLANT REQUEST FOR EXEMPTION TO 10 CFR 50.71(c)(4)
FINAL SAFFFY ANALYSIS REPORT UPDA.TE SCIIEDULE i
Ladies and Gentlemen:
Pursuant to 10 CFR 50.12(a), Southern Nuclear Operating Company (SNC) hereby requests an exemption fmm the requirements of 10 CFR 50.71(c)(4) regarding submission of revisions to the Updated Final Safety Analysis Report ('UFS AR) for the Vogtle Electric Generating Plant (VEGP).
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 after each refueling outage provided the interval between successive updates does not exceed 24 months. VEGP is a two-unit plant site having a common UFSAR. Therefore, given a literal interpretation of the languag contained in 10 CFR 50.71(c)(4), SNC would be required to update the VEGP UFSAR within 6 months after each respective unit's refueling outage.
When a two-unit plant site such as VEGP shares 1 common UFSAR and has staggered 18 month Spnng/ Fall refueling outages,10 CFR 50.71(c)(4) has the net effect of potentially requiring the j
UFSAR to be updated more frequently than every 12 months. The rule change that was published
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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 limiting the frequency of required updates. However, as written, the burden reduction can only be /, I{3 realized by single-unit facilities, or multiple-unit facilities that maintain separte UFS ARs for each unit, neith::r of v hich is the case for EGP. Consequently, since VEGP is h enu!ciple-unit facility with a common UFSAR, the phrase "cach refueling outage" in 10 CFR 50.71(OH) increases rather than decreases the regulatory burden, which is contrary to the intent of the rule.
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 UFSAR. However, one comment suggested that a li:msee of a multiple-unit facility should designate the refueling schedule of one of the units to coahush the schedule for revision of the common UFSAR. In response to that comment, the NRC stated ; hat for " multiple facilities sharir:g a common FSAR, licensees will have maximum ficxibility for scheduling updates on a case-by-case basis." Accordingly, SNC interpreted this
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U.S. Nuclear Regulatory Commission Page 2 reporting requirement to its most logical application and stated intent - that being to the reduction of regulatory burden. He employment of this practice has been discussed with the NRC staff and is also included in docketal correspondence which contains our UFSAR wision submittal schedule. Dec to recent discussions with the NRC staff, SNC now understands that a literal interpretation of 10 CFR 50.71(c)(4) requires a specific NRC exemption to utilize this schedule; although, this interpretation is in opposition to the burden-reduction premise of the rule.
%c requested exemption will allow periodic updates of the VEGP UFSAR once per fuel cycle,
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within 6 months followin8 completion of each VEGP Unit 2 refueling outage, not to exceed 24 mon'hs from the last submittal. Derefore, the regulatcry 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 VEGP UFS AR 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 accetstable. Because the primary intent of the rule as stated by the NRC was burden e
reduction and the current NRC staffinterpretation of the rule would increase the regulatory burden of the VEGP staff by requiring updates to the common VEGP UFSAR within 6 months after each respective unit's refueling octage, this exemption request qualifies under 10 CFR 50.12(a)(2)(ii).
This exemption is allowed by law, vill not present an undue isk to the public health and safety, and is consistent with common deft.nse and security and is otherwise in the public interest.
Sincerely, C. K. McCoy CKMfrMM cc: Southern Nuclear Ooeratinn Comoany Mr. J. B. Beasley, Jr.
Mr. M. Sheibani NORMS U. S. Nuclear Reculatory Commission Mr. L. A. Reyes, Region 11 Administratcr Mr. D. H. Jaffe, Semor Project Manager, NRR Mr. J. Zeiler, NRC Senior Resident Inspector, Vogtle LCV-1076
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