ML20211B750
| ML20211B750 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/27/1986 |
| From: | Butler W Office of Nuclear Reactor Regulation |
| To: | Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8606110882 | |
| Download: ML20211B750 (5) | |
Text
- ga ucg*'o, UNITED STATES E'
'j NUCLEAR REGULATORY COMMISSION
, #. (
4 E
WASHINGTON, D. C. 20555 t
o
%...../
MAY 2 71986 Docket Nos. 50-352/353 Mr. Edward G. Bauer, Jr.
Vice President and General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101
Dear Mr. Bauer:
SUBJECT:
UPDATED FINAL SAFETY ANALYSIS REPORT This is in regards to your letter of February 11, 1986 wherein you requested a schedular exemption from the requirement of 10 CFR 50.71(e) to submit an updated Final Safety Analysis Report (FSAR) within 24 months of the date of issuance of the operating license. Based on the issuance of the Limerick Generating Station, Unit 1 operating license on August 8, 1985 this would require an updated FSAR to be submitted by August 8, 1987. Since Unit 2 remains under construction you requested an exemption that would permit filing the Updated FSAR (UFSAR) within 12 months of the issuance of a full power operating license for Limerick Unit 2.
As you are aware, the regulations in 10 CFR 50.12 regarding exemptions have recently been revised such that the Commission will not consider granting an exemption unless special circumstances are present.
10 CFR 50.12(a)(2). As stated in the Federal Register announcing issuance of the Final Rule in this regard:
The Commission expects the intent of its regulations to be met and normally this requires conforming to the regulations as stated. There are circumstances, however, where 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.
50 FR 50764-50778, December 12, 1985.
We believe that it is the intent of your letter to address just such a situation as contemplated in the preceeding paragraph. Accordingly, your request should be augmented with a discussion and justification regarding the special circum-stances which attend this situation.
It is quite likely that upon examination you will find that the special circumstances defined in 10 CFR 50.12(a)(2)(ii),
(iii) or (v) may apply. However your augmented application for the exemption should identify and justify the special circumstances present in this case.
8606110882 860527 PDR ADOCK 05000352 P
. t 9
1
-2_
Such an exemption as sought by your letter of February 11, 1986 will apply to the requirements of paragraph 50.71(e)(3)(i) and will not relieve the Philadelphia Electric Company from the requirements of 10 CFR 50.71 for maintenance of the original FSAR during this interim period.
Furthermore, we request that your application be augmented to include a commitment to include a summary description with each amendment to the FSAR submitted in this interim period which identifies the Unit to which the change applies and provides a narrative discussion summary of the design changes or significant issues which are reflected in the amended FSAR pages.
Sincerely, Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing cc: See next page i
I l
I
f I
Mr. Edward G. Bauer, Jr Limerick Generating Station Philadelphia Electric Company Units 1 & 2 cc:
Troy B. Conner, Jr., Esquire Chairman Board of Supervisors of Conner and Wetterhahn Limerick Township 1747 Pennsylvania Ave, N.W.
646 West Ridge Pike Washington, D. C.
20006 Limerick, Pennsylvania 19468 Barry M. Hartman Frank R. Romano, Chairman Office of General Counsel Air & Water Pollution Patrol Post Office Box 11775 61 Forest Avenue Harrisburg, Pennsylvania 17108 Ambler, Pennsylvania 19002 Federic M. Went:
Dept. of Environmental Resources County Solicitor ATTN: Director, Office Radiologic County of Montgomery Health Courthouse P. O. Box 2063 Norristown, Pennsylvania 19404 Harrisburg, Pennsylvania 17105 Mr. John Franz, Plant Manager Ms. M. Mulligan Limerick Generating Station Limerick Ecology Action Post Office Box A 762 Queen St.
Saratoga, Pennsylvania 19464 Pottstown, Pennsylvania 19464 Mr. Karl Abraham Thomas Gerusky, Director Public Affairs Officer Bureau of Radiation Protection Region I Dept. of Enviromental Resources U.S. Nuclear Regulatory Commission 5th Floor, Fulton Bank Bldg.
631 Park Avenue Third and Locust Streets King of Prussia, PA 19806 Harrisburg, Pennsylvania 17120 4
Mr. Gene Kelly Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 47 Sanatoga, Pennsylvania 19464 Governor's Office of State Planning and Development ATTN: Coordinator, Pennsylvania State Clearinghouse P. O. Box 1323 Harrisburg, Pennsylvania 17102
r
.i Philadelphia Electric Company Limerick Generating Station 1/2 cc:
Director, Pennsylvania Emergency Angus Love, Esq.
Management Agency 107 East Main Street Basement, Transportation &
Norristown, Pennsylvania 19402 Safety Building Harrisburg, Pennsylvania 17120 Helen F. Hoyt, Chairman Administrative Judge Robert L. Anthony Atomic Safety & Licensing Board Friends of the Earth U.S. Nuclear Regulatory Commission of the Delaware Valley Washington, D. C.
20555 103 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Dr. Jerry Harbour Administrative Judge Atomic Safety & Licensing Board Kathryn S. Lewis, Esq.
U.S. Nuclear Regulatory Commission Municipal Services Bldg.
Washington, D. C.
20555 15th and JFK Blvd.
Philadelphia, Pennsylvania 19102 Dr. Richard F. Cole Administrative Judge David Wersan, Esq.
Atomic Safety & Licensing Board Assistant Consumer Advocate U.S. Nuclear Regulatory Commission Office of Consumer Advocate Washington, D. C.
20555 1425 Strawberry Square Harrisburg, Pennsylvania 17120 Mr. Spence W. Perry, Esq.
Associate General Counsel Federal Emergency Management Agency Room 840 500 C Street, S.W.
Washington, D. C.
20472 Mr. J. T. Robb, NS-1 Philadelphia Electric Company 2301 Market Street Philadelphia, Pennylsvania 19101 Timothy R. S. Campbell, Director Department of Emergency Services 14 East Biddle Street West Chester, Pennsylvania 19380
F go _yL
. Such an exemption as sought by your letter of February 11, 1986 will apply to the requirements of paragraph 50.71(e)(3)(i) and will not relieve the Philadelphia Electric Company from the requirements of 10 CFR 50.71 for maintenance of the original FSAR during this interim period. Furthermore, we request that your application be augmented to include a commitment to include a summary description with each amendment to the FSAR submitted in this interim period which identifies the Unit to which the change applies and provides a narrative discussion summary of the design changes or significant issues which are reflected in the amended FSAR pages.
Sincerely, Original signed by Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing cc: See next page DISTRIBUTION
-Docket File 4 NRC PDR Local PDR PD#4 Reading RBernero Vogler, OELD JPartlow EJordan BGrimes M0'Brien REMartin ACRS (10)
RGallo MA'
+
w P 4/fl1 OEL jPD#4/D
/
/Vti n:1b WButler 05/ y/86 05/{$/86 05/
86