ML20127J302

Forwards Comments on Draft Full Power License NPF-19, Including Proposed Changes to Listed License Conditions Re Reactor Core Power Levels,Pump & Valve Inservice Testing Program,Fire Protection Program & Generic Ltr 83-28

ML20127J302
Person / Time
Site:	Limerick
Issue date:	05/17/1985
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Butler W Office of Nuclear Reactor Regulation
References
CON-#285-060, CON-#285-60, CON-285-60 GL-83-28, OL, NUDOCS 8505210441
Download: ML20127J302 (5)

Text

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OW PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 .

JOHN 5. KEMPE R V IC E-PR ESID E NT afeGesosanseeG AND RESE ARCD4 Mr. Walter R. Butler, Chief Licensing Branch No. 2 Division of Licensing

' U.S. Nuclear Regulatory Conmission MAY 171985 Washington, D.C. 20555

SUBJECT:

Limerick Generating Station, Unit 1 Draft Full Power Operating License NPF-39

REFERENCES:

1) T. M. Novak to E. G. Bauer, Jr., letter dated May 1, 1985 FILE: GOVT 1-1 (NRC)

Dear Mr. Butler:

We have reviewed the draft Limerick Generating Station Unit 1 Facility Operating License transmitted to us via the reference letter and offer the conments listed in the attachment, together with the -

basis for each. Please contact us if you require any additional information.

Sincerely, VAdf JWC/dg/05108506 Attachnent -

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(See Attached Service List)

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.cc: Judge Helen F.:Hoyt Judge Jerry Harbour Judge Richard F. Cole Troy B. Conner, Jr., Esq.

Ann P. Hodgdon, Esq.

Mr. Frank R. Romano Mr. Robert L.. Anthony Ms. Phyllis Zitzer Charles W. Elliot, Esq.

-Zort G. Ferkin, Esq.

Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus R. Love, Esq.

David Wersan, Esq.

Robert J. Sugarman, Esq.

Martha W. Bush, Esq. ,,

Spence W. Perry, Esq.

Jay M. Gutierrez, Esq.

Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panet Docket & Service Section Mr. James Wiggins Mr. Timothy R. S. Campbell a

m ATTACFNENT

, . COPNENTS ON THE LIMERICK GENERATING STATION, UNIT 1 DRAFT LICENSE, NPF-39

'(PROPOSED CHANGES ARE UNDERLINED) ,

'COFNENT 1: -License Condition 2.C.(1), Line 1, change to read:

~"The licensee is authorized to operate the facility at steady state reactor core power levels. . .".

BASIS: This change is consistent with the licenses for Peach Bottom Atcrnic Power Station, Units 2 and 3, (DPR-44 and DPR-56) and the IIcensing basis for Limerick, as ',

described in the FSAR.

COFNENT 2: License Condition 2.C.(4), Line 3, change to read:

" Pursuant to 10CFR Part 50.59, the relief Identifled in the Purp and Valve Inservice Testing Program Plan for the Limerick Generating Station Unit 1, Revision 5 ~

dated Decenter 13, 1984...".

BASIS: Via the Decenter 13, 1984 letter from J. S. Kemper to H. R. Denton, PECo transmitted Revision 5 to the Punp and Valve Inservice Testing Program Plan which, together with the unaffected Revision 4 pages, reflects our current comnitments which will be implemented to satisfy the Inservice testing requirements of subsections IWP and IWV of ASME Section XI.

COPHENT 3: License Condition 2.C.(5)a, Line 2, change to read:

"The licensee shall maintain in effect all provisions of the approved fire protection program for safety-related systems and equipment and for other plant areas containing fire hazards that could adversely affect safety-related systems...."

License Condition 2.C.(5)b, Line 2, change to read:

"The Ilcensee shall mako no change to features of the approved fire protection program for safety-related systems and equipment and for other plant areas containing fire hazards that could adversely affect safety-related systems...."

License Condition 2.C.(5)c, Line 2, change to read:

"The licensee may make changes to features of the approved fire protection program for safety-related .

systems and equipment and for other plant areas containing fire hazards that could adversely affect safety-related systems...."

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tBASIS: These changes are to distinguish'the safe shutdown 4

.-- . aspects from econanic.or property protection aspects of-

, > the fire protection program and thus make the IIcense condition consistent wIth Branch Technical Position BTP.

CNB 9.5-1 (Formerly ASPCB 9.5-1) as endorsed by 10 CFR:

h- 50.48.

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L COPNENT % License Condition 2.C.(7Xb), Line 2, change to read:

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"The Ilcensee shall have the Safety Parameter Display System initial 1Y operable...".

The' wording change'Is consistent'with our

l. . BASIS' rli 9, 1985 L. Amenchnent Request.

[  : COP 9 elT 5: - License Condition' 2.C.(10).

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This LI'ense c Condition Should Be Deleted:

w "The licensee shall inclement the requirements of Generic Letter 83-28 on 'a schedule which is consistent with that given in its Novenber 10, 1983, May 8, 1984,

and August 31, 1984 letters."

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s l BASIS:- .The-Itcense condition Inappropriately requires that PEco Inglement conmitments which are not yet approved

'W by the PRC, and are st.bject to change as a result of the NRC's ongoing review (see March 19, 1985 letter from A. Schwencer to E. G. Bauer, Jr., Recuest for -

l . t, . Additional Information - Preliminary Staff Review of

_ Generic Letter 83-28 Responses. Limerick Generatina n-

, W Station)..

COPNENT' 6: License Condition 2.C.(12), Line 3, change to read:

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"... provide automatic and diverse isolation signals to u the reactor enclosure cooling water suDD1Y and return lines to the recirculation cues inboard and outboard

^,, Isolation valves and the drywell chilled water supply and return line outboard Isolation valves."

BASIS: The. change is to clarify the IIcense condition u -i s consistent with the referenced sections of SER and

!V SSER-3."

..COPNENT 7: License Condition 2.C (13), change to read:

g "The licensee'shall, -prior to startup following the l l s first refueling outage, have completed modifications to Y

!. the existing remote shutdown system to provide a redundant safety-related method of achieving safe shutdown conditions wIthout 1Iftino' leads or addIna Junpers.

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The modificationg to be completed shall Hd/d Wdd6 ditMd/ be those described in the licensee's letters i # dated,AFil18and22,1985 which allow for the operation of the B RHR pym, the B RHtSW pum and the B ESW pum

. from the respective pum breaker compartments by the Installation of transfer switches. 6/ digd/6did sit 41fildtIM i M !t6 %did did6 did16didd 16 dil6fdd6td

, ditH 18 &lt 58/59 .dfd f6Md f6 Bd Adddi6tdWidl The 1Icensee

, shall perform necessary tests prior to startup following the first refueling outage to demonstrate the operability of the modified system."

Paragraph 3 Should Be Deleted:

" Alternate modifications performed without prior Ccrimission approval shall be reported to the NRC staff together with the supporting analysis, no later than thirty (30) days following startup from the first refueling outage."

BASIS: The change is to clarify the Ilcense condition.

COMMENT 8: License Condition 2.C.(17).

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We understand that the NRC is re-evaluating Ilcense L/ '

< conditions for emergency planning in light of the

1. ASLB's May 2, 1985 Partial Initial Decision and other recent developments.

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j. COPHENT 9: License Condition 2.E., Lines 13 and 17, change to read:

"... Limerick Generating Station Safeguards Contingency Plan," dated March, 1981 (Letter of March 17, 1981) as revised by changes dated April,1982 (Letter of April 16, 1982) and March,1985 (Letter of April 2,1985h

" Limerick Generating Station Plant Security Personnel Training and Qualification Plan," dated September,1981 (Letter of Septenter 30, 1981) as revised by changes dated March, 1982 (Letter of April 1, 1982)t August, 1982 (Letter of August 13, 1982) and April, 198' (Letter of April 19, 1985)".

BASIS: The changes provide an updated conmitment ilsting.

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