ML20206H628

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Forwards Application for Amend to License DPR-66,consisting of Change Request 138,moving Fire Protection Requirements from Tech Specs to Plant Procedures & Updated Fsar.Fee Paid
ML20206H628
Person / Time
Site: Beaver Valley
Issue date: 04/07/1987
From: Sieber J
DUQUESNE LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206H260 List:
References
GL-86-10, NUDOCS 8704150403
Download: ML20206H628 (2)


Text

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T415 Telephone (412) 393-6000 "R'E l

  • Shippingport, PA 15077-0004 April 7, 1987 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Proposed Operating License Change Request No. 138 Gentlemen:

Enclosed are:

1. One (1) original and thirty-seven (37) copies of an Application for Amendment to our Operating License to remove the fire protection requirements from the technical specifications. The following changes are proposed; delete sections 3.3.3.6, 3.7.14.1, 3.7.14.2, 3.7.14.3, 3.7.14.4, 3.7.14.5, 3.7.15, and associated bases, 6.2.2.f, 6.4.2 and revise license condition 2.c(5). A note.(next page is 3/4 3-49) has been added to page 3/4 3-46 to reflect the removal of the fire detection specification. This page was previously submitted for NRC review in Technical Specification Change No. 122 dated February 24, 1987. The I change to the license condition reflects the guidance provided in Section F of Generic Letter 86-10, Implementation of Fire Protection Requirements. Compliance with fire protection requirements will not be degraded by removing them from the technical specifications since they will be maintained in appropriate plant procedures and the UFSAR which will ensure changes are reviewed by the Onsite Safety Committee (OSC). These changes are consistent with the NRC and industry efforts to simplify the technical specifications. The requested changes will be implemented l upon NRC. approval and after the necessary procedure and l UFSAR changes have been incorporated. This submittal is consistent with the BV-2 approach to fire protection which is currently in the NRC technical specification review process. Since the UFSAR changes must be incorporated prior to removing the fire protection requirements from the technical specifications, we would like to negotiate the effective date for this technical specification knendment with the NRC Project Manager.

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Benvar Valley Powar. Station, Unit No. 1 J':Dockst No. 50-334, Licensa No. DPR-66.

Proposed Operating License-Change Raquest No. 138' Page 2 5

~

In License- Condition -2.c.5' .(Fire Protection Program), DLC understands the phrase " implement and maintain.in effect all

. provisions of the approved fire protection program" to-mean-i that all provisions of the approved fire protection program which.-(1)~ pertain to NRC requirements,.or (2) affect plant'
safety. or the ability.to achieve and maintain safe shutdown in the event of a fire, are required.to be implemented'and maintained.

i l- The reasons .for which DLC has established a fire protection

program for BVPS-1 are as follows:

l -

NRC regulations

_ Insurance company guidelines Industry codes.and standards 4

DLC standard practices i -

Protection of DLC's capital investment-1

! Many of the provisicas of the fire protection program

! resulting from these -reasons may_ not coincide with areas i which affect the NRC's review or plant safety. .However, DLC ,

! -believes that it is beneficial from the standpoints of i efficiency and effectiveness to include all- provisions related to fire protection in one integrated program rather j than having several separate programs.

These changes have been reviewed by -the OSC and. ORC and i determined to be safe and do not involve an unreviewed safety question.

i

2. Thirty-eight (38) copies of documents setforth in Attachment A -

, the change in technical . specifications, _ Attachment B - the'no t'

significant hazards consideration, Attachment C - which provides UFSAR changes as additional' supporting' information, and Attachment D -

administrative procedures provided as additional supporting information.

A check in the amount of $150.00.will be provided-under separate l cover in payment .of the license amendment application fee in accordance with 10 CFR 170.

1

.Very truly yours, k

bel . D. Sieber i Vice President, Nuclear i

Attachment f

o 1

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