ML20211H940
| ML20211H940 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/26/1997 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9710070205 | |
| Download: ML20211H940 (4) | |
Text
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Statlin Support De7.criment
" 1 10CFR50.12
.PECO-NUCLEAR-nm e 965 ChestertxtxA Boutovard A Unit of PECO Energy _
Wayne, PA 19087 5691 September 26,1997
)
Docket No. 50-171 License No. DPR-12 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Subject.
Peach Bottom Atomic Power Station, Unit 1 Request for Exemption from Certain Requirements of 10CFR50.71,
" Maintenance of Records, Making of Reports" Gentlemen:
In accordance with 10CFR50.12, PECO Energy Company hereby requests an exemption from certain provisions of 10CFR50.71, " Maintenance of Records, Making of Reports," for Peach Bottom Atomic Power Station, Unit 1, which has been licensed to remain in a SAFSTOR status. Specifically, an exemption is requested from submitting final ssfety analysis report (FSAR) pages, on a replacement-page basis, accom aanied by a list which identifies the current pages of the FSAR as stipulatec by 10CFR50.71(e)(1).'
The enclosed exemption request will not present an undue risk to the public health and safety, and is considered corisistent with the common defense and security. This exemption demonstrates that FSAR revisions will be filed every 24 months to satisfy the underlying purpose of 10CFR50.71(e).- Implementing 1
the methods required for strict compliance with 10CFR50.71(e)(1) would not increase the level of public health and safety, and would result in undue
. hardship and cost not considered when the regulation was adopted. Thus, the criteria for issuance of this exemption are met in accordance with 10CFR50.12.
- If you have any questions, please do not hesitate to contact us.
Very truly yours, g
.d. h if,
G. A. Hunger, r.
M, Director - Licensing.
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Enclosure:
Attachment cc:
H.-J. Miller, Administrator, Region I, USNRC R. S. Barkley, USNRC Senior Resident inspector, PBAPS 10 C 0 J () ~,
R. R. Janati, Commonwealth of Pennsylvania 971007o2o5 970926 PDR ADOCK o50oo171 P_
4 Y
l ATTACHMENT PBAPS Unit 1 10CFR50.71 Exemption Request e
1.0 Background
P'esch Bottom Atomic Power Station (PBAPS) Unit 1 is a high temperature, gas cooled reactor that operated from June 1967 to its final shutdown on October 31,1974. All spent fuel has been removed from the site and the fuel poo: has been drained and decontaminated. All radioactive liquids have been removod, ard accessible areas of the facility decontaminated. PBAPS Unit 1 is licensed to remain in a SAFSTOR status until December 24,2015.
l On July 29,1996 a final rule on Decommissioning of Nuclear Reactoi, was published in the Federal Register. The purpose of the rule w95 to clarify cmbiguitles in the current rule, codify procedures that reduce the regulatory burden, provius greater flexibility, and allow for greater public participation in the dacommissioning process.
The changes imposed by the rule involved the decommissioning process and amendments to Part 50 to properly cover the transition of a facility from operating to permanent shutdown status. Also, changes, were made that affoc.ed shutdown facilities.
PBAPS Unit 1 was licensed without a Fli,al Safety Analysis Report (FSAR). PBAPS Unit i submitted a Final Hazards Summary Report as part of the licensing process.
PECO Energy Company (PECO Energy) procedure AG-124, ' Control of Unit 1 Activities,' identifies those documents wh ch define the licensing basis for PBAPS Unit 1 as the Safety Analysis Report (SAR). The following documents are considered part of the SAR:
- 1. The Original Decommissioning Plan and Safety Analysis Report (July 1,1974)
- 2. The Possession-Only License and Technical Specifications
- 3. Referenced Documents in the Possession-Only License
- 4. NRC Safety Evaluations associated with the decommissioned facility
- 5. PECO Energy Safety Evaluations concerning Unit 1 The PBAPS Unit 1 License at 2.0 specifies that the license is subject to 10CFR50.59, 20 Specific Exemption Requested 10CFR50.71(e) requires that the FSAR originally submitted as part of the application for the operating license be updated periodically to assure that the information included in the FSAR contains the latest material developed.10CFR50.71(e)(1) states that the licensee shall submit revisions containing updated information to the NRC on a replacement-page basis that is accompanied by a list which identifies the ctrrent pages of the FSAR following page replacement.10CFR50.82(a)(9)(i) requires that the license termination plan be a supplement to the FSAR cr equivalent, in lieu of submitting updated information on a replacement-page basis, PECO Energy proposes to submit in their entirety all safety evaluations concerning PBAPS Unit 1. To date, only three safety evaluations have been completed for PBAPS Unit 1 that affect the SAR. Summaries of each of these safety evaluations had been provided in accordance with the requirements of 10CFR50.59. In the future, the safety evaluations, not the summaries, for PBAPS Unit 1 will be submitted at the same time that our annual 10CFR50.59 report for PBAPS is submitted. In addition an index of the documents that comprise the SAR for Unit 1 will be provided to the NRC in the 50.59 annual report.
i 3.0 rpatisfaction of Exemption Criteria Exemptions from the requirements of NRC regulations are authorized by 10CFR50,12.
An exemption will be granted if it is authorized by law; will not present an undue risk to the public health and safety; is consistent with the common defense and security; and is supporied by one or more of the special circumstances identified in 10CFR50.12(a)(2).
The exemption is authorized by law because the underlying requirement is established by an NRC rule for which an exemption may be granted under 10CFR50.12. Updated information for PBAPS Unit i SAR will be provided in accordance with 10CFR50.71(e)(4) so that this exemption will not result in undue risk to the public health and safety. Common defense and security are not affected since no fuel exists at Unit 1. Two of the special circumstances recognized by 10CFR50,12(a)(2) are l
applicable, as described below.
Reporting required by strict compilance with 10CFR50,71 e)(1) is not necessary to achieve the underlying purpose of the rule. The SAR will(be maintained as described in section 1.0, Reporting will be performed by submitting any subsequent safety evaluations and an up-to-date index of documents that comprise the SAR. By submitting these PECO Energy safety evaluations, the NRC will have the complete SAR with revisions described in section 1.0 in their possession, in addition, the hardship and costs associated with compilation of an FSAR to allow for updating information on a replacement page basis would be significantly in excess of those contemplated when the final rule on Decommissioning of Nuclear Reactors was adopted, in fact,10CFR50.82 refers to supplementing an FSAR or equivalent.
Submittal of all safety evaluations concerning PBAPS Unit i achieves the underlying purpose of 10CFR50,71(e) in a cost-effective manner, in conclusion, the criteria of 10CFR50.12 are satisfied and the exemption should be granted.
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