ML20203F900
| ML20203F900 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/28/1986 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Butler W Office of Nuclear Reactor Regulation |
| References | |
| CON-#386-159 OL, NUDOCS 8607310202 | |
| Download: ML20203F900 (4) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 JOHN 5 KEMPER VICE PRESIDENT July 28, 1986
' ' ' ' ~ " " ' ' ' " ' " " ' " ' "
Mr. W. R. Butler, Director Docket Nos.:
50-352 BWR Project Directorate No. 4 50-353 U. S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Updated Final Safety Analysis Report
REFERENCES:
Letter from J. S. Kemper (PEco) to H. R. Denton, dated February 11, 1986 Letter from W. R. Butler to E. G. Bauer (PEco), dated May 27, 1986 FILE:
GOVT 1-1 NRC (FSAR)
Dear Mr. Butler:
Our letter of February 11, 1986 requested a schedular exemption from the requirements of 10CFR50.71(e) to submit an Updated Final Safety Analysis Report within 24 months of the date of issuance of the operating license. Your letter of May 27, 1986 acknowledged this request, but indicated that a discussion and justification regarding the special circumstances relevant to the request be provided. This letter augments our previous request with identification and justification of the special circumstances present in this case.
We have determined that the following "special circumstances" as defined by 10CFR50.12 are applicable to the requested exemption.
50.12 (a)(2)(ii):
" 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."
The underlying purpose of the requirement for periodic updating of the FSAR after facility operation commences is to assure that accurate and timely information on a facility and its design is readily available.
As stated in our exemption request, the existing FSAR will be kept current by periodic amendments during the period that the D607310202 060728 f)
PDR ADOCK 05000352 hO P
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= _ _ _. _ _ _ _._
I requested exemption is in effect. Thus updating the existing FSAR during the interim will assure that the NRC is supplied with accurate information regarding both units on a timely basis. Changes to the FSAR l
which will be filed periodically include the following:
l l
1)
Revisions necessary to reflect changes made to Unit I under l
the provisions of 10CFR50.59. These submittals will be made no later than six months after the modification has been j
implemented; 4
i 2)
Revisions applicable to Unit 2; i*
3)
Typographical corrections; and I
4)
Changes to the Quality Assurance Program description as required by 10CFR50.54(a)(3) and 10CFR50.55(f)(3).
The periodic submittal of such information in the form of page changes to the existing FSAR will assure that underlying purpose of the rule is met.
50.12(a)(2)(iii):
j~
" Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted..."
In order to fulfill the requirements of 50.71(e) it would be necessary to generate and maintain a separate FSAR for each Limerick unit because of the differences between the operational dates of the l
two units. Although the existing Limerick FSAR accurately describes i
both units, extensive review and rewording would be required to edit l
and compile an UFSAR applicable to only Unit 1. The costs associated with the preparation of a separate FSAR for Unit I are substantial and have been estimated to be in excess of $3 million.
In addition, undue l
difficulties would be presented by the administrative problems j
associated with the maintenance of a second FSAR, such as maintaining consistency between documents; logging and tracking additional FSAR j
changes; establishing and maintaining new FSAR change procedures; j
maintaining separate distributions for FSAR revisions; coordination of editorial activities; and establishing additional document retention capabilities. We do not believe that it was the Commission's intent to impose hardships such as these when the regulation was adopted.
I 50.12(a)(2) (v):
l "The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant l
has made good faith efforts to comply with the l
regulation."
I The request for exemption from the requirements of 50.71(e) is l
schedular in nature. As described in our February ll, 1986 letter, j
the exemption would only defer the submittal of the updated FSAR until i
12 months after the issuance of a full power operating license for Limerick Unit 2.
As stated above, the information contained in the i
I existing FSAR, as periodically revised, will be the same as required by aj
. 50.71(e) and, revisions to the FSAR will be provided at least as frequently as required by the rule, thus clearly complying with the intent of the regulation.
Thus, on balance it would not be equitable or in the public interest to require literal adherence to regulations particularly where a particular requirement applied to a specific plant would not result in an improvement in overall safety or a reduction in risk to the public.
As further requested in your letter of May 27, 1986, we shall provide a summary description with each amendment to the FSAR submitted during the schedular exemption period. The summary description will identify the unit to which a particular change applies and will provide a narrative summary of the significant design changes or issues which are reflected in the amended FSAR pages.
Sincerely,
(/W l f
,/
RDC/mb/07038601 Attachment Copy to:
R. E. Martin, NRC Project Manager See Attached Service List
cc: Troy B. Conner, Jr., Esq.
Benjamin H. Vogler, Esq.
Mr. Frank R. Romano Mr. Robert L. Anthony Ms. Maureen Mulligan Charles W. Elliot, Esq.
Barry M. Hartman, Esq.
Mr. Thcmas Gerusky Director, Penna. Emergency Management Agency Angus R. Love, Esq.
David Wersan, Esq.
Robert J. Sugarman, Esq.
Kathryn S. Lewis, Esq.
Spence W. Perry, Esq.
Jay M. Gutierrez, Esq.
Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel Docket & Service Section Mr. E. M. Kelly Mr. Timothy R. S. Campbell
.