ML20211A058
| ML20211A058 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/20/1986 |
| From: | Butler W Office of Nuclear Reactor Regulation |
| To: | Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| GL-86-03, GL-86-3, NUDOCS 8606110038 | |
| Download: ML20211A058 (5) | |
Text
p mer UNITED STATES
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o,h NUCLEAR REGULATORY COMMISSION j
WASHINGTON, D. C. 20555
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MAY 2 01986 Docket No. 50-352 Mr. Edward G. Bauer, Jr.
Vice President and General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101
Dear Mr. Bauer:
SUBJECT:
APPLICATION FOR AMENDMENT OF OPERATING LICENSE CONCERNING PLANT STAFF ORGANIZATION AND POSITION TITLES The Philadelphia Electric Company (PECo) submitted an application for amend-ment to the Limerick Generating Station, Unit 1 operating license, dated April 1, 1986.
In the application, PEC0 requested that the facility Technical Specifications be changed to reflect changes to plant staff position titles and to the plant staff organization. We have found that the application is defi-cient in several respects, and while we do not believe that it will be difficult for PECo to remedy these deficiencies, we do feel that they should be corrected prior to the staff's further consideration of the application. Accordingly, we have not yet made a proposed determination with respect to significant hazards consideration. We request your response to the matters discussed below prior to our further consideration of the application.
The deficiencies in the application concern the format and content of the safety analyses provided in support of the requested changes to the Technical Specifica-tions and the analysis provided for the proposed no significant hazards considera-tion determination.
There are some rather limited safety analyses provided for each of the changes or types of changes proposed for the Technical Specifications. There is some information in the significant hazards discussion which could constitute part of the safety analysis. However, it should be kept in mind that there is no intrinsic safety significance to the no significant hazards consideration (48 Federal Register (14865) April 6, 1983). Thus, the staff does not choose to base its safety finding on the information provided in the application's no significant hazards consideration discussion. We request that a discretely identified safety analysis discussion be provided for each of the changes or types of changes. This analysis should address the significance of the proposed changes with respect to the effectiveness of the organization's response to safety issues. This discussion should include consideration of the adequacy of the quorum proposed for the PORC.
8606110038 060520 PDR ADOCK 00000352 P
5 Generic Letter 86-03, dated February 10, 1986, addressed the need for an adequate analysis in support of the application's proposed no significant hazards con-sideration determination. The specific need here is for a technical dis-cus,sion/ analysis in the application to support each of the changes or types or changes. A citation to one of the examples of actions which are "likely" or "not likely" to involve significant hazards considerations is not sufficient.
In this regard, a brief technical discussion of the basis for the application's conclusions with respect to the three factors of 10 CFR 50.92 is requested.
Should you have any questions regarding this letter, please contact the staff's Project Manager, Mr. R. E. Martin, for the Limerick Generating Station.
Sincerely, original signed by Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing cc: See next page Distribution T Dockettf11e "NRC'PDR" Local PDR PD#4 Rdg RBernero Vogler, OELD JPartlow EJordan BGrimes RMartin M0'Brien ACRS (10)
- Previously concurred:
PD#4/PM BWF0 PD#4/D
- RMartin
- DVassalo WButler 05/07/86 05/08/86 05/20/86
Generic Letter 86-03, dated February 10, 1986, addressed the need for an adequa'te analysis in support of the application's proposed no significant hazards con-sideration determination. The specific need here is for a technical dis-cussion/ analysis in the application to support each of the changes or types of changes. A citation to one of the examples of actions which are "likely" or "not likely" to involve significant hazards considerations is not sufficient.
In this regard, a brief technical discussion of the basis for the application's conclusions with respect to the three factors of 10 CFR 50.92 is requested.
Should you have any questions regarding this letter, please contact the staff's Project Manager, Mr. R. E. Martin, for the Limerick Generating Station.
Sincerely, Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing c-- ext page I
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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 & Wate'r Pollution Patrol Post Office Box 11775 61 Forest Avenue Harrisburg, Pennsylvania 17108 Ambler, Pennsylvania 19002 Federic M. Wentz 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 Mr. Gene Kelly Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 47 Sanatoga, Pennsylvania 19464 Governor's Office of State l
Planning and Development I
ATTN: Coordinator, Pennsylvania j
State Clearinghouse i
P. O. Box 1323 Harrisburg, Pennsylvania 17102 l
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Philadelphia Electric Company
- Limerick Generating Station 1/2 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 Timethy R. S. Campbell, Director Department of Emergency Services 14 East Biddle Street West Chester, Pennsylvania 19380 i
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