ML20082J400

Application for Amends to Licenses NPF-39 & NPF-85, Consisting of TS Change Requests 94-51 Delete Independent Tech Review Section from TS, 94-52 Delete Nrb Review Section from TS, 94-53 Delete Nrb Audit Section from Ts

ML20082J400
Person / Time
Site:	Limerick
Issue date:	04/06/1995
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20082J403	List: ML20082J400 ML20082J423
References
NUDOCS 9504180236
Download: ML20082J400 (4)

Text

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Ctation support Dep rtmw.t -

_=h, 10CFR50.54(a)(3)(1) 10CFR50.90 w:r-( ( PECO Energy Company Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne, PA 19087-5691 April 6,1995 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 l

U. S. Nuclear Regule. tory Commission .

ATTN: Document Control Desk l Wastengton. DC 20555 s i

SUBJECT:

Limerick Generating Station, Units 1 and 2 Response to Request for Additional Information Regarding Technical Specifications Change Request Nos. 94-51-0, 94-52-0, and 94-53-0 Gentlemen:

By letter dated November 21,1994, in accordance with 10 CFR 50.90, PECO Energy '

Company (PECO) requested five (5) specific changes to the Limerick (LGS) Technical Specifications (TS), Administrative Section. Three (3) of the proposed changes are,94-51-0  ;

" Delete Independent Technical Review Section from TS,' 94-52-0 ' Delete NRB Review Section  :

from TS,' and 94-53-0 ' Delete NRB Audit Section from TS.' in addition, by letter dated 4

November 21,1994, PECO Energy proposed changes to the LGS Quality Assurance Program j

. Description (QAPD) in accordance with 10 CF3 50.54(a)(3). By letter dated March 6,1995 the 1' i NRC requested additional information pertain!ng to these three TS changes effecting the 2 QAPD. )

Attachment 1 to this letter provides a restatement of the NRC's request and PECO's response.

l Attachment 2 to this letter contains supplemental Updated Final Safety Analysis Report

, (UFSAR) pages, supporting the QAPD proposed changes which reflect the NRC request for j additional information. This information is being submitted under affirmation, and the required affidavit is enclosed.

! If you have any questions, please do not hesitate to contact us, i

i' Very truly yours, l

. a.

G. A. Hunger, Jr.,

Director - Licensing 4 f l

-Attachments cc: T. T. Martin, Administrator, Region I, USNRC (w/ attachment and enclosure) )

i N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachment and enclosure)'

R. R. Janati, PA Bureau of Radiological Protection (w/ attachment and enclosure)

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. P_ . PoR- .

l COMMONWEALTH OF PENNSYLVANIA  :

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I COUNTY OF CHESTER  :

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W. H. Smith, lit, being first duly sworn, deposes and says: That he is Vice President of ,

i PECO Energy Company, the Applicant herein; that he has read the enclosed additional information involving Technical Specifications Change Request Nos. 94-51-0, 94-52-0, and ,

l 94-534 for Umerick Generating Station, Unit 1 and Unit 2, Facility Operating License Nos.  !

i 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.

1

> ,/ ',

/

Vice President r

Subscribed and sworn to before me this /A

%day of 1995. j I

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i // j Notary Public 1 --

NotaialSeal ErcaASxci, Navy R2 i

TredythriTwp Chester My Commsson ExpresJuly10, 995 l

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e Attachment 1 ,

LIMERICK GENERATING STATION UNIT 1 AND UNIT 2  ;

Docket Nos, ,

50-352 50-353 ,

License Nos.

NPF-39 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST ~

NOS. 94-51-0, 94-52-0, and 94-53-0  ;

REQUEST FOR ADDITIONAL INFORMATION

' Changes Affecting TS Administrative Section* I i

1PAGE j 1

i 1

Page 1 of 11 1

.' \'

Reouest for AdditionalInformation Limerick Generatina Staten. Units 1 and 2 Quality Assurance Prooram Description (QAPD) )

The following addtional information was requested by the NRC by letter dried March 6,1996.

NRC REQUEST 1. Reference TSCR 94-51-0.

The staff finds that the revised independent Technical Heview Program provisions meet the appropriate acceptance crteria of Section 13.4 of NUREG-0800, and conform to Section 5.5 of the ISTS. However, the staff position is that these requirements should remain under the control of the provisions I of 10 CFR 50.54(a)(3) which is not applicable to Section 13.4 l of the UFSAR. Therefore, the staff finds the deletion of this requirement from the TS unacceptable, unions it is relocated in the QAPD in Section 17 of the UFSAR.

PECO RESPONSE The independent Technical Review Program provisions will be deleted from TS and relocated from Chapter 13 of the Limerick .)

UFSAR to Chapter 17 of the UFSAR which is controlled under  ;

the provisions of 10 CFR 50.54(a)(3).

NRC REQUEST 2. Reference TSCR 94-52-0 and 94-53-0.

The staff position is that the relocation requirements should  !

remain under the control of the provisions of 10 CFR 50.54(a)(3). Therefore the staff requires that these koms [NRB-review responsibilities and audit details] be relocated to the' QAPD. -

PECO RESPONSE The NRB review responsibilities and audit details will be ,

deleted from TS and relocated from Chapter 13 of the Limerick  !

UFSAR to Chapter 17 of the UFSAR wf:Ich is controlled under the provisions of 10 CFR 50.54(a)(3).'

NRC REQUEST 3. Reference QAPD Changes.

The restructuring of the ISEG function to the Independent Technical Review Program is acceptable. However, the staff's position is that the independent Technical Review Program should remain under the control of 10 CFR 50.54(a)(3).

Therefore, the staff finds the deletion of Section 17.2.1.2.3.2 unacceptable.-  !

j PECO RESPONSE The independent Technical Review Program function will be deleted from TS and relocated from Chapter 13 of the Limerick UFSAR to Chapter 17 of the UFSAR which is controlled under the provisions of 10 CFR 50.54(a)(3). '

The above intsisi-i;vn supplements the information pertaining to proposed TS Change Request Nos. 94-51-0,94-52-0, and 94-53-0, submitted by letter dated November 21,1994.

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