ML20237B601

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Discusses Updated Final Fsar.Util Committed to Submit Changes to FSAR Periodically,Including Revs Necessary to Reflect Changes Made Per 10CFR50.59.Submittals to Be Made No Later than 6 Months After Mod Implemented & Changes Made
ML20237B601
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 12/08/1987
From: Butler W
Office of Nuclear Reactor Regulation
To: Bauer E
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8712160390
Download: ML20237B601 (6)


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o UNITED STATES

~g NUCLEAR REGULATORY COMMISSION c

E WASHINGTON, D. C. 20555

  • s\\,,,p /a December 8, 1987 l

Docket Nos. 50-352/353 Mr. Edward G. Bauer, Jr.

Vice President and General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101

Dear Mr. Bauer:

I

SUBJECT:

UPDATED FINAL SAFETY ANALYSIS REPORT i'

RE:

Limerick Generating Station, Units 1 and 2 Your letter of February 11,19R6, supplemented by your letter of July 28, 1986, requested a schedular exemption from the requirement of 10 CFR 50.71(e) to submit an updated Final Safety Anelysis Report (FSAR) within 24 months of the i

date of issuance of the operating license.

Based on the issuance of the Limerick Generating Station, Unit 1 operating license on August 8, 1985, this would have required an updated FSAR to be submitted by August 8, 1987.

Because Unit 2 remains under construction, you requested an exemption that would permit filing the Updated FSAR (UFSAR) within 12 months of the issuance of a full power operating license for Limerick Unit 2.

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Currently, one FSAR for the Limerick Generating Station covers Unit 1 (which is oparating) and Unit 2 (on which construction is about 73% completed).

Unit 3

2 is essentially identical in design to Unit 1.

The intent of 50.71(e)(4) is i

to require a licensee to update its FSAR at least annually and that the updated FSAR " reflect all changes up to a maximum of six months prior to the date of filing."

- You have comitted to submit changes to the FSAR periodically as follows:

1 1.

Revisions necessary to reflect changes made to Unit i under the provisions of 10 CFR 50.59. These submittals will be made no later than six months after the modification has been implemented; 2.

Revisions applicable to Unit 2, identifying differences, if any, between Units; 3.

Typographical corrections; and 4.

Changes to the Quality Assurance Program description as required by 10 CFR 50.54(a)(3) and 10 CFR 50.55(f)(3).

In accordance with these comitments, you submitted Revision 49 to the FSAR by your letter of June 30, 1987.

You stated that Revision 49 " brings the Report up-to-date as of at least April 15, 1987." By letter of October 30, 1987, you submitted Revision 50 to the FSAR. You stated that the latest revision " brings 8712160390 071208 PDR ADOCK 05000352 P

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the Report up-to-date as of at least August 18, 1987." We understand that the current FSAR centains all the required information for both units at Limerick and is complete as of August 18, 1987. Any differences between Units 1 and 2 I

have been identified.

For example, there are stresses and cumulative usage factors given for the Unit 1 piping, but no values listed for the Unit 2 piping because the Unit has not been operating.

We conclude that the periodic revisions to the combined FSAR for Limerick Units 1 and ? that you have been submitting, and which you have committed to centinue to submit, satisfy 10 CFR 50.71(el and that there is no need for an exemption.

l With respect to revisions to the FSAR, vou have be., submitting an original J

and 37 copies of all amendments.

In the FEDERAL ret ' STER of November 6,1986 j

(51 FR 40307), the Conrnission established revised sub, ittal requirements.

We j

regard the amendments to the FSAR as falling under tha ' requirements' applicable to an Updated FSAR which specifies a signed original ah' 12 copies.

Since issuance of the Unit 1 operating license, you have been providing in Appendix B (Volume 17) of the FSAR a summary description of the changes and issues that are reflected in each revision to the FSAR.

In some cases, you specifically described the modifications that were the reasons for changing e i

drawing (e.g., the revisions to Figures 7.3-21 and 9.4-5 in Amendment 49). We l

would appreciate it if you would provide a similar specific discussion of each modification of which to focus our review effort.

Sincerelv, Walter R. Butler, Director l

Project Directorate I-2 i

Division of Reactor Projects I/II Office of Nuclear Reactor Regulation cc: See next page

Q 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 & Water Pollution Patrol Post Office Box 11775 61 Fcrest 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 Mr. David Stone Limerick Generating Station Limerick Ecology Action, Inc.

Post Office Box A P. O. Box 761 Sanatoga, Pennsylvania 19464 Pottstown, Pennsylvania 19464 Mr. Karl Abraham Thomas Gerusky, Director Public Affairs Officer Bureau of Radiation Protection Region I PA Dept. of Environmental Resources U.S. Nuclear Regulatory Commission P. O. Box 2063 631 Park Avenue Harrisburg, Pennsylvania 17120 King of Prussir, PA 19406 Mr. Gene Kelly Governor's Office of State Senior Resident Inspector Planning and Development U.S. Nuclear Regulatory Commission ATTN: Coordinator, Pennsylvania P. O. Box 47 State Clearinghouse Sanatoga, Pennsylvania 19464 P. O. Box 1323 Harrisburg, Pennsylvania 17102

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Philadelphia Electric Company Limerick Generating Station 1/2

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CC:

Director, Pennsylvania Emergency 1

Management Agency Basement. Transportation &

Safety Building Harrisburg, Pennsylvania 17120 1

Robert L. Anthony Angus Love, Esq.

l Friends of the Earth 107 East Main Street l

of the Delaware Valley Norristown, Pennsylvania 19402 103 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Helen F. Hoyt, Chairman

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Charles E. Rainey, Jr., Esquire Administrative Judge l

Chief Assistant City Solicitor Atomic Safety & Licensing Board Law Department, City of Philadelphia U.S. Nuclear Regulatory Commission One Reading Center Washington, D. C.

20555 1101 Market Street, 5th Floor l

Philadelphia, PA 19107 David Wersan, Esq.

Dr. Jerry Harbour Assistant Consumer Advocate Administrative Judge Office of Consumer Advocate Atomic Safety & Licensing Board 1425 Strawberry Square U.S. Nuclear Regulatory Commission l

Harrisburg, Pennsylvania 17120 Washington, D. C.

20555 1

Dr. Richard F. Cole Mr. Spence W. Perry, Esq.

Administrative Judge Associate General Counsel Atomic Safety & Licensing Board Federal Emergency Manageoent Agency l

U.S. Nuclear Regulatory Commission Room 840 I

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Washington, D. C.

20555 500 C St., S.W.

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Washington, D. C.

20472 l

Mr. J. T. Robb, NS-1 l

Philadelphia Electric Company 2301 Market Street Philadelphia, Pennylsvania 19101 j

i Timothy R. S. Campbell, Director Department of Emergency Services 14 East Biddle Street West Chester, Pennsylvania 19380 i

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I the Report up-to-date as of at least August 18, 1987." We understand that the i

current FSAR contains all the required information for both units at Limerick j

and is complete as of August 18, 1987. Any differences between Units 1 and 2

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have been identified.

For example, there are stresses and cumulative usage

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factors given for the Unit 1 piping, but no values listed for the Unit 2 l

piping because the Unit has rot been operating.

We conclude that the periodic revisions to the combined FSAR for Limerick Units 1 and 2 that you have been submitting, and which you have committed to centinue to submit, satisfy 10 CFR 50.71(e) and that there is no need for an exemption.

With respect to revisions to the FSAR, you have been submitting an original and 37 copies of all amendments.

In the FEDERAL REGISTER of November 6, 1986 (51 FR 40307), the Commission established revised submittal requirements. We regard the amendments to the FSAR as falling under the requirements applicable to an Updated FSAR, which specifies a signed original and 12 copies.

Since issuance of the Unit 1 operating license, you have been providing in Appendix B (Volume 17) of the FSAR e summary description of the changes and issues that are reflected in each revision to the FSAR.

In some cases, you l

specifically described the modifications that were the reasons for changing a drawing (e.g., the revisions to Figures 7.3-21 and 9.4-5 in Amendment 49). We would appreciate it if you would provide a similar specific discussion of each modification of which to focus our review effort.

Sincerely,

/s/

Walter R. Butler, Director Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation l

cc:

See next page DISTRIBUTION Docket File-NRC PDR/LPDR PDI-2 Reading SVarga/BBoger VButler P0'Brien RClark/RMartin 0GC-Bethesda EJordan/JPartlow ACRS(10)

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revision " brings the Report up-to-date as of at least August 18, 1987." Any differences between Units 1 and 2 have been identified.

For example, there are stresses and cumulative usage factors given for the Unit 1 piping, but no values listed for the Unit 2 piping since the Unit has not been operating.

We conclude that the periodic revisions to the combined FSAR for Limerick Units 1 and 2 that you have been submitting)- and which you have committed to continue to submit - satisfy 10 CFR 50.71(e and that there is no need for an exemption.

With respect to revisions to the FSAR, you have been submitting an original and 37 copies of all amendments.

In the Federal Register of November 6,1986 (51 FR 40307), the Commission established revised submittal requirements. We regard the amendments to the FSAR as falling under the requirements of 2.(6) Updated FSAR, which specifies a signed original and 10 copies.

Since issuance of the Unit 1 operating license, you have been providing in Appendix B (Volume 17) of the FSAR a summary description of the changes and issues that are reflected in each revision to the FSAR.

In some cases, you l

specifically described the modifications that were the reasons for changing a j

drawing (e.g., the revisions to Figures 7.3-21 and 9.4-5 in Amendment 49).

We would appreciate it if you would provide a similar specific discussion of each modification to focus our review effort.

I Sincerely, l

Walter R. Butler Director Project Directorate I-2 Division of Reactor Projects I/II

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Office of Nuclear Reactor Regulation cc:

See next page l

l DISTRIBUTION l

. Docket: Fi le, l

NRC PDR/LPDR PDI-2 Reading SVarga BBoger WButler l

M0'Brien RClark/RMartin 0GC-Bethesda EJordan JPartlow i

ACRS(10) 1 Previously concurred

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PDI-2/Pd PDI-2/D DRPI/AD 0p M0'Brien RClarkfmf-WButler BBoger R$WpV\\

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