ML20202F342

Requests Exemption from Requirements of 10CFR50.71(e)(4) Re Submission of Revisions to UFSARs for Plant.Background & Justification Encl

ML20202F342
Person / Time
Site:	Sequoyah
Issue date:	12/01/1997
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9712090065
Download: ML20202F342 (5)

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Tonnessee Valley Authority, Post Offee Box 2000, SoddyOaisy, Tennessee 37379-2000 December 1, 1997 10 CFR 50.12 U.S. Nuclear Regulatory Commission ATTN: Document Control Deik Washington, D.C. 20555 J-Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authcrity ) 50-328 SEQUOYAH KUCLEAP, PIANT (SQN) - REQUEST FOR EXEMPTION IN ACCORDANCE WITH 10 CFR 50.12, REGULATORY BURDEN REDUCTION:

10 CFR 50.71(e) (4)

Pursuant to the provisions of 10 CFR 50.12(a), TVA requests an exemption from the requirements of 10 CFR 50.71(e) (4) regarding submission of the revisions to the Updated Final Safety Analysis Reports (UFSARs) for the SQN Nuclear Plant.

Should TVA's exemption request be granted, SON would be permittea to update its single, unified UFSAR for the two-unit SON site six months-after Unit 2 refueling outages.

The enclosure to this letter describes the backg,:ound and the g justification for seeking this exemption.

Please direct questions concerning this issne to me at (423) 843-7170 or J. D. Smith at (423) 843-6672.

Sincere:

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V s W t Licensing and Industry Affairs Manager Enclosure cc: See page 2 h I

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U.S. Nuclear Regulatory Commission Page 2 December 1, 1997 cc (Enclosure):

Mr. R. W. Hernan, Project Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 h NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igot Ferry Road Soddy-Daisy, Tennessee 37379-3624 L

s Regional Administrator <

U.S. Nuclear Regulatory Commission

, Region II 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303-3415 s.

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ENCLOSURE TENNESSEE VALLEY AUTHORITY 1

SEQUOYAH NUCLEAR PLAWT (SQN)

UNITS 1 AND 2 REQUEST FOR EXEMPTION IN ACCORDANCE WITH 10 CFR 50.12, REGULATORY BURDEN REDUCTION: 10 CFR 50.71(e) (4)

BACKGROUND

=-_ TVA hereby requests an exemption for SON from the reporting frequency stated in 10 CFR 50.71(e), which requires that Updated Final Safety Analysis Report (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 as a final rule in the Federal Register dated August 31, 1992 (57 FR 39353), and became effective October 1, 1992.

According to the Summary and Analysis contained in the Federal ,

Register Notice accompanying the final rule, in the case of multiple facilities sharing a common GTSAR, licensees will have maximum flexibility for scheduling updates on a case-by-case basis.

TVA interpreted this reporting requirement, according to its stated intent, as a reduction of regulatory burden. Accordingly, TVA, by letter dated November 16, 1992, submitted a letter describing SON's new frequency schedule for submitting UFSAR updates and 10 CFR 50.59 reports. TVA's letter indicated that SON's reporting schedule for its UFSt.R and 50.59 reports would be based on SON's Unit 2 refueling outages. This has been SON's process since that time.

_s Where there is one shared, common UFSAR for a multiple unit s it.e ,

a, as in the case of SON, literal application of 10 CFR 50.71(e) (4) y would require evcessive revisions of the same UFSAR document im within six months after each unit's refueling outage.

Accordingly, for the purpose of retaini.ng SQN's current FSAR update schedule and to obviate the need for excessive revisions, TVA requests an exemption f rom 10 CFR 50.71(e) (4) to allow revisions to SON's UFSAR to be submitted within 6 months from the E-1 "r _

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n end of the Unit 2 refueling outages, at an interval not to exceed 24 months. Based upon the information and schedule communicated in TVA's November 16, 199,2 letter, TVA's intent has never been to exceed the 24 month interval between successive revisions.

, TVA also notes that 10 CFR 50.59 allows licer. sees the option of submitting 10 CFR 50.59 reports annually or along with FSAR updates as required by 10 CFR 50.71(e). TVA chose to submit SQN's 10 CFR 50.59 reports along with SON's UFSAR and plans to continue submitting 10 CPR 50.59 reports in conjunction with '

SON's FSAR updates.

RFQUEST Upon NRC approval of this exemption from the Code of Federal Regulations, TVA plans to submit UFSAR revisions for SON Units 1 and 2, 6 months after each Unit 2 refueling outage not to exceed 24 months between successive revisions. ,

JUSTIFICATION 10 CFR 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. TVA believes that such special circumstances are present in this instance to warrant exemption from the regulatory requirements of 50.71 (e) . Specifically, Secticns (ii) and (iii) of 10 CFR 50.12 (a) (2) state, (LL) Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

TVA considers the purpose of 10 CFR 50.71(e) (4) to be the promotion of regulatory efficiency and the redo' tion of refilatory burdens. Literal application of this rule would have the opposite effect.

(iii) Compliance would result in undue ha.rdship or other costs that are significantly in excess of those contemplated whan the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated; E-2

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,5 Based upon TVA's SQN site having one common UFSAR shared by multiple units, literal cc:npliance would result in undue hardship and costs in excess of that contemplated under the rule. Literal application of the rule would significantly affect manpower resources and costs now required to electronically incorporate UFSAR changes, republish the large document (SON's UFSAR totals more than 3,000 pages), and transmit the revision package to NRC-and other document holders.

This exemption is administrative in nature and will not present an undue' risk to the public health and safety. The proposed exemption is consistent with common defense and security and is otherwise in the public interest.

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