ML20077D549
| ML20077D549 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/02/1994 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20077D554 | List: |
| References | |
| GL-86-10, GL-88-12, NUDOCS 9412090086 | |
| Download: ML20077D549 (6) | |
Text
Str,ti:n copport DiptrtmInt
, s jh 10CFR50.90
,.t y PECO ENERGY =mgi=A,,
965 Choterbrook Boulevard Wayne, PA M87 5691 ,
December 2,1994 Docket Nos. 50452 50-353 License Nos. NPF-39 NPF-85 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Technical Specifications Change Request No.89-104 Relocation of Fire Protection Requirements Gentlemen:
PECO Energy Company is submitting Technical Specifications (TS) Change Request No. 89-10-0 in accordance with 10 CFR 50.90, requesting a change to the TS (i.e., Appendix A) of Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2.
The proposed changes will relocate the LGS TS Fire Protection Requirements to Licensee controlled documents consistent with NRC Generic Letter (GL) 86-10 " Implementation of Fire Protection Requirements", and GL 88-12, " Removal of Fire Protection Requirements from Technical Specifications."
Information supporting this TS Change Request is contained in Attachment 1 to this letter, and the proposed replacement pages for the LGS TS are contained in Attachment 2. This TS Change Request is being submitted under affirmation, and the associated affidavit is enclosed.
We request that, if approved, this TS Change Request for LGS, Units 1 and 2, be approved prior to June 1,1995 and become effective within 30 days of issuance.
If you have any questions, please do not hesitate to contact us.
Very truly yours, 4#
G. A. Hungeyr,,p>. Jr.,
Director - Licensing CyQj1 Attachments Enclosure cc: T. T. Martin, Administrator, Region I, USNRC (w/ attachments and enclosure)
N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachments and enclosure)
R. R. Janati, PA Bureau of Radiological Protection (w/ attachments and enclosure) 9412090086 941202 PDR '
P ADOCK 05000352 \
l I
l COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF CHESTER l
W. H. Smith, lil, being first duly sworn, deposes and says: That he is Vice President of PECO Energy Company, the Applicant herein; that he has read the enclosed Technical Specifications Change Request No.89-104, " Relocation of Fire Protection Requirements," for Limerick Generating Station, Unit 1 and Unit 2, Facility Operating License Nos. NPF-39 and NPF-85, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, Information and belief.
Vice sident i Subscribed and swoni to before me ti;!sh2 ay n
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.p s Notary Public NotanalSeal Erico A Sarton, Nota y Pulic Trah*nnTS.Cheste Count /
My Coninisson ExpresJ410,1995 1
ATTACHMENT 1 UMERICK GENERATING STATION UNIT 1 AND UNIT 2 Docket Nos.
50-352 50-353 License Nos.
NPF-39 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST NO. 89-10-0
" Relocation of Fire Protection Requirements" Supporting Information for Changes - 3 PAGES l
1 l
PAGE 1 l
PECO Energy Company, licensee under Facility Operating Ucense Nos. NPF-39 and NPF-85 for Umerick Generating Station (LGS), Units 1 and 2, requests that the Technical Specifications (TS) contained in Appendix A to the Operating Ucense be amended, as proposed herein, to remove the Fire Protection Requirements from TS, prior to June 1,1995.
Discussion and Descriotion of the Prooosed Chanaes The proposed changes will relocate the LGS TS Fire Protection Requirements to Licensee controlled documents consistent with NRC Generic Letter (GL) 86-10 " implementation of Fire Protection Requirements,"
and GL 88-12, " Removal of Fire Protection Requirements from Technical Specifications."
These proposed changes will revise the LGS Unit 1 and Unit 2, license condition pertaining to the Fire Protection Program (FPP) and relocate the LGS Fire Protection Requirements (i.e., Umiting Conditions for Operation (LCO), and Surveillance Requirements (SR)) from TS to the LGS Technical Requirements Manual (TRM), Fire Protection Section. The following changes are proposed.
- 1. Current Fire Protection license cond!! ion,2. C. (3), contained in the Unit 1 and 2 Facility Operating License (FOL), is being replaced with a new standard Fire Protection operating license condition consistent with that recommended by GL 86-10, as follows.
"PECO Energy Company shall implement and maintain in effect all provisions of the approved Fire Prctection Program as described in the Updated Final Safety Analysis Report for the facility, and as approved in the Safety Evaluation Report dated August 1983, through supplement 9, subject to the following provision:
PECO Energy Company may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire."
The proposed FOL pages are contained in Attachment 2 of this request.
- 2. The following TS sections along with their associated Bases are being deleted from TS and will be relocated to the TRM.
Section 3/4.3.7.9, " Fire Detection Instrumentation" 1 Section 3/4.7.6, " Fire Suppression Systems" Section 3/4.7.7, " Fire Rated Assemblies" .
Section 6.2.2.e, " Unit Staff", " Fire Brigade" l Two new pages 3/4.3-92 and 3/4.7-19 are being inserted containing a note which states that the l fire protection LCOs and SRs have been relocated to the TRM. The affected TS pages are shown 1 in Attachment 2 of this request. l
- 3. Section 6.5.1.6 will be revised to include on-site review (Plant Operations Review Committee) ,
responsibility for the FPP and implementing procedures and the submittal of recommended changes I l
to the Nuclear Review Board (NRB).
l The affected TS pages are included in Attachment 2 of this request. Changes are indicated by a vertical bar in the right hand margin of the affected TS page.
1
PAGE 2 JIl ety f Assessment This TS Change Request is consistent with NRC GL 86-10 " Implementation of Fire Protection Requirements,"
and GL 88-12 " Removal of Fire Protection Requirements from Technical Specifications." NRC GL 86-10, and GL 88-12 encourage licensees to apply for an amendment to their Facility Operating Licenses (FOLs) that will (1) replace the current license condition regarding fire protection with a new standard license condition, (2) relocate requirements for fire protection systems from TS,3) remove fire brigade staffing from TS, and (4) add administrative controls to TS to ensure relocated requirements continue to be subject to controls consistent with those for other programs implemented by license conditions.
The proposed changes to the LGS license condition preclude future changes to the approved FPP without prior NRC approval if those changes would adversely affect the ability to achieve and maintain safe shut-down conditions in the event of a fire.
The proposed changes also iemove the fire protection requirements (i.e., LCOs and SRs) from TS, remove fire brigade staffing from TS, and relocate these requirements to the LGS TRM, Fire Protection Section, which is a licensee controlled document. Review and approval of the TRM and changes thereto will be in accordance with TS Section 6.0. " Administrative Controls" and subject to review in accordance with 10 CFR 50.59. The LGS Updated Final Safety Analysis Report (UFSAR), Chapter 9.5.1 " Fire Protection Program,"
Appendix 9A
- Fire Protection Evaluation Report," and proposed FOL license condition contain the major commitments and controls that form the basis for the NRC-approved FPP. The UFSAR will also reference (permitted by GL 88-12) the TRM which will define portions of the FPP as identified in the NRC's Safety Analysis Reports. Changes that result from the relocation of the TS fire protection requirements to the TRM will be identified in TS and the UFSAR, as to their location. The proposed changes to relocate TS requirements do not affect the requirements to perform surveillance testing and the manner of performing surveillance testing is adequately described in plant procedures.
In accordance with GL 88-12, TS Administrative Controls Section 6.0 will be augmented to support the Fire Protection Program. Similar to the LGS Emergency Plan and the Security Plan, TS Section 6.5.1.6 will be revised to include on-site review (i.e., Plant Operations Review Committee) responsibility for the FPP and implementing procedures and the submittal of recommended changes to an off-site group (i.e., Nuclear Review Board (NRB)). Currently, LGS TS Section 6.8 " Procedures and Programs," requires that procedures ;
be established, implemented, and maintained for the FPP as recommended by GL 88-12. In addition, TS i Section 6.5.2.8, requiring a NRB audit of the FPP at least once every two years, will be retained in TS. j information Sucoortina a Findina of No Sianificant Hazards Consideration !
We have concluded that the proposed changes to the Limerick Generating Station (LGS), Unit 1 and Unit i 2, Technical Specifications (TS), which will remove Fire Protection Requirements from Technical 1 Specifications (TS), do not involve a Significant Hazards Consideration. In support of this determination, l an evaluation of each of the three (3) standards, set forth in 10 CFR 50.92 is provided below.
- 1. The proposed Technical Specifications chanaes do not involve a sianificant increase in the orobability or consecuences of an accident oreviousiv evaluated.
l The proposed changes are administrative in nature and are consistent with NRC GL 86-10 and GL 88-12.
Removal of Fire Protection Program (FPP) requirements does not affect any fire protection equipment nor plant equipment important to safety, or involve any physical modifications to plant structures, systems or components, and therefore is not associated with an accident initiator or accident mitigator and can not affect the probability of occurrence of an accident or increase the consequences of an accident. The i licensee controlled Technical Requirements Manual (TRM) containing the relocated requirements will be I maintained in accordance with TS Section 6.0. " Administrative Controls" and subject to review in accordance with 10 CFR 50.59. Since future changes to the FFP (i.e., Updated Final Safety Analysis Report and the TRM) wi'l be evaluated per 10 CFR 50.59, no increase (significant or insignificant) in the probability or consequences of an accident previously evaluated will be allowed. Therefore, these changes do not involve j i
l
PAGE 3 a signifhant increase in the probability or consequences of an accident previously evaluated.
- 2. The crocosed TS chanaes do not create the oossibility of a new or different kind of accident from any accident oreviousiv evaluated.
The changes will not alter the plant configuration (no new or different type of equipment will be installed) or create changes in methods governing normal plant operation that wili introduce new failure modes.
These changes will not impose different requirements and proper control of information will be maintained.
These changes will not alter assumptions made in the safety analysis and licensing basis. Therefore, these changes do not create the possibility of a new or different kind of accident previously evaluated.
- 3. The orocosed TS chanaes do not involve a slanificant reduction in a marain of safety.
The proposed changes are administrative in nature and are consistent with NRC GL 86-10 and GL 88-12.
The changes will not reduce the margin of safety since they have no impact on any safety analysis assumptions or sequence of events used in any accident analysis. In addition, any future changes to the FPP will be evaluated per the requirements of 10 CFR 50.59. Therefore, the changes do not involve a significant reduction in a margin of safety.
Information Sucoortina an Environmental Assessment An Environmental Assessment is not required for the Technical Specifications changes proposed by this Change Request because the requested changes to the Limerick Generating Station. Units 1 and 2 TS conform to the criteria for ' actions eligible for categorical exclusion," as specified in 10 CFR 51.22(c)(9). The requested changes will have no impact on the environment. The proposed TS changes do not involve a Significant Hazards Consideration as discussed in the preceding safety assessment section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any effluent that may be released offsite. In addition, the proposed TS changes do not involve a significant increase in Individual or cumulative occupational radiation exposure.
Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the Limerick Generating Station, Units 1 and 2, Technical Specifications, and have concluded that they do not involve an unreviewed safety question.