ML20203K216
| ML20203K216 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/20/1998 |
| From: | Abney T TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9803050023 | |
| Download: ML20203K216 (5) | |
Text
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En Tent euce Vaney Autt ority Post ON e lion 9000. Dec atu, A'at>a= a 3M.09 r
February 20, 1998 10 CFR 50.12 U.S. Nuclear Regalatory Commission ATTN:
Document Control Des):
Washington, D.C.
20555 Gentlemen:
In the Matter of
)
Docket Nos. 50-259 Tennessee Valley Authority
)
50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 - UPDATED FINAL SAFETY ANALYSIS REPORT SUBMISSION PER 10 CFR 50.71(e) (4)
- REQUEST FOR EXEMPTION IN ACCORDANCE WITH 10 CFR 50.12, REGULATORY BURDEN REDUCTION 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 revisions to the Updated Final Safety Analysis Report (UFSAR) for the BFN Nuclear Plant.
Shoald TVA's exemption request be granted, BFN would be permitted to update its single, unified UFSAR for the three-unit BFN site six months following Unit 2 refueling outages.
The enclosure to this letter provides the background and the justification for seeking this exemption.
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U.S. Nuclear Regulatory Commission Page 2 February 20, 1996 If you have c.ny questions regarding this axemption request, plcase contact ne at (205) 729-2636 Sfacerely,
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Manager of L!.gensitg a
and Industry Affa irs i3 v-Enclosure b5 cc (Enclosure):
Mr. Albert W. De Agazio, Project Manager U.S. Nuclear Regulatory Commission Onc White Flint, North 11a55 Rcckville Pike Rockvillc, Maryland 20852 Mr. Ma-k S. Lesser, " ranch Chief U.S. Nuclear Regulatory Commission Region II 61 Forsyth 9treet, S.W.
Juite 23T85 Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry Nuc] ear Plant 10833 Shaw R 3d Athens, Alabama 35611
ENCLOSURO TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1, 2, AND 3 UPDATED FINAI. SAFETY ANALYSIS REPORT (UFSAR) l SUBMISS !ON PER 10 CFR 50. 71 (e) (4)
REQUEST FOR EXEMPTION IN ACCORDANCE WITH 10 CFR 50.12 w
e p, f; Background and Justification TE.
~
i TVA requests an exemption for BFN from the reporting frequency stated in 10 CFR 50.71Ie), which requires that Updated Final Safetir Analysis Report (UFSAR) revisions be filed annually or six 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 tho Federal Register dated August 31, 1992 (57 FR 39353), ar.d became ef fective 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 JESAR, licenseas 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 May 23, 1995, submitted a description of BFN's new frequency / schedule for submitting UFSAR updates.
TVA's letter stated that BF' 's repcrting schedule for its UFSAR would be based on the Unit 2 refuelina catages.
This has been BEN's process since that time.
Where there is one shared, common 1.'SAR for a multiple unit site, as in the case of BEN, literal applic tion of 10 CFR 50.71(e) (4)
&tould require excessive revisions of the same UFSAR document within six months af ter each unit's refueling outage.
Therefore, for the purpose of retaining BFN's current FSAR update schedule and to preclude the need for excessive revisions, TVA requests an exemption f rom 10 CFR 30. 71 (e) (4 ) to allow revisions to BEN's UFSAR to be submitted within six months from the 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 May 23, 1995 letter, TVA's intent has always been to never exceed the 24 month interval between succersive UFSAR revisions.
It should also be noted that 10 CFR 50.59 allows the licencee the option of submitting 10 CFR 50.59 reports annually or along with FSAR updater as required by 10 CFR 5^.71 (e).
TVA chose to submit BFN's 10 CFR 50.59 reports as part of the BFN Annual Operating i
Report and plans to continue this practice.
Upon NRC approval of this exemption from the Code of Federal l
Regulations, TVA plans to submit UFSAR revisions for BFN on the following basis:
BFN Units 1, 2,
and 3 UFSAR:
Six nonths after each Unit 2 refueling outage not to exceed 24 months between successive revisions.
10 CFR 50.12 authorizes the Commission, upon application by 1ny interested person, to grant exemptions from the requirement; af 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) (4).
Specifically, Sections (ii) and (iii) of 10 CFR 50.12 (a) (2) state, (ii) "Applicacion of the regulation in the particular.
circumstances would not serve the underl ing f
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 pramotion or regulatory efficiency and the reduction of regulatory burdens.
Literal application of this rule would have the opposite effect.
(iii) " Compliance would result in undue hardship or ather costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated;"
Since BEN has one common UFSAR shared by multiple units, literal compliance would result in undue hardship and costs in excess of that contemplated under the rule.
Literal app'4 cation of the E2 3
9 4
rule would significantly affect manpower resources and costs now required to-electronically incorporate UFSAR changes, re ablish the_large document (BFN's UFSAR totals more than.3,000 pages),
nd transmit the revision-package to NRC and other document
!ders.
-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 e
otherwise in-the public interest.
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