ML20195E189

Forwards Response to Issues Addressed in Generic Ltr 88-12 Re OL Change Request 138.Attachment a Includes Revised Tech Spec Pages Updated to Incorporate Amends Issued Since Original Submittal

ML20195E189
Person / Time
Site:	Beaver Valley
Issue date:	11/01/1988
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20195E194	List: ML20195E189 ML20195E201
References
GL-88-12, NUDOCS 8811070288
Download: ML20195E189 (4)

Text

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pTg aver Va Pew Staten Shmngport PA150774004 70%,%

mmms November 1, 1988 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 Generic Letter 88-12 Response Gentlemen:

Operating License Chango Roquest No. 138 proposed removal of the fire protection requirements from the technical specifications in accordance with Generic Letter 86-10.

NRC review of this proposed change has boon on hold pending issuance of additional gonoric guidance.

Generic Letter 88-12 (Removal of Fire Protection Requirements from Technical Specifications) has boon issued to provide that additional guidance.

The following provides our response to the issues addressed in Generic Letter 88-12 concerning Operating License Change Roquest No.

I 138.

Attachment A

includes revised technical specification pages updated to incorporate amendments issued since the original submittal.

The proposed technical specification changes provided are identical to those provided in the original submittal.

Attachmonts B,

C, D

and E

(Safety Analysis, No Significant Hazard Evaluation, t

UFSAR

pages, and Site Administrative Procedure (SAP) 9D) have boon revised to roflect the current submittal format and address the guidance provided in Generic Letter 88-12.

The additional requirements described in Generic Letter 88-12 are addressed in our original submittal, therefore, no additional technical specification changes are required.

The following discussion providos cach Generic Letter 88-12 requirement along with our response:

1.

The NRC approved Firo Protection Program must be incorporated into the FSAR and submitted with the certification required by 10 CFR 50.71(o) (2), as requested by Generic Letter 86-10.

l Resoonse:

Attachment D

contains the applicablo UFSAR i

l changes that wore incorporated in the latest updato in l

accordance with 10 CPR 50.71(c) (2).

s:41oragCKee ee,,e,

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05000334 P

PDC

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Benvor VallGy Pow 0r Station, Unit No. 1

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Docket No. 50-334, License No. DPR-66 Page 2 1

2.

The Limiting Conditions for operation and Surveillance Requirements associated with fire detection systems, fire suppression

systems, fire barriers, and the administrative controls that address fire brigade staffing would be relocated from the TS.

The existing administrative controls related to fire protection audits are to be retained in TS.

Response

The requirements for the abovo items have been incorporated into SAP-9D.

Fire Protection audits will continue to be required in accordance with Administrative Control 6.5.2.8.

No change to this section is required.

i i

3.

All operational conditions, remedial

actions, and test requirements presently included in the TS for these systems, as well as the fire brigade staffing requirements, shall be incorporated into the Fire Protection Program.

The remedial actions include shutdowns currently required by TS 3.0.3 when a

LCo and its associated action requirements cannot be mot.

ResDongs:

The requirement of specification 3.7.14.1 Action b

for applicability to the provisions of specification 3.0.3 will be incorporated into the administrativo proceduros (SAP 9D) at the time of approval and issuance of this T.S. amendment.

Attachment E contains the proposed marked-up change to SAP 9D Tablo 1 (page 21) as noted above.

All other operational conditions, remedial actions and test requirements presently included in the TS for those systems have boon incorporated into SAP 9D.

4.

The standard fire protection licenso condition in Generic Letter 86-10 must be included in the licenso.

Any other i

current fire protection license conditions shall be removed.

Rosconso:

The standard fire protection licenso condition is included in Attachment A

and replaces the curront firo protection licenso condition 2.C. (5).

This licenso chango l

is described in Attachmonts B

and C.

This is consistant l

with the original submittal.

S.

The Administrativo Controls section of the TS shall bo I

augmented to support the Fire Protection Program.

This I

shall be accomplished by additions to two specifications.

I

First, the Onsite Safety Committee (OSC) shall be given L

responsibility for the review of the Fire Protection Program and implementing proceduros and the submittal of recommended changes to the offsite Review Committee (ORC).

Second, Firo l

Protection Program implomontation shall be added to the list j

of elements for which written proceduros shall bo established, implomonted, and maintained.

[

t a

Betver Vallcy Powar Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Page 3 Responsg:

Generic Letter 88-12 provides marked pages of the Westinghouse Standard Technical Specifications (STS) to serve as a

model for the changes to the administrative controls.

However, it also allows for plants technical specifications that differ from the STS by stating that additions to the administrative controls for the Fire Protection Program should be proposed that are consistent with the administrative controls for the Emergency and Security Plans.

The current administrative controls for our Fire Protection Program, Emergency, and Security Plans are:

1)

Specification 6.5.1.6, the OSC is responsible for the review of all procedures required by specification 6.8 and changes of intent thereto.

2)

Specification 6.8.1, written procedures shall be established, implemented and maintained covoring:

item d.

Security Plan, item e.

Emergency Plans, and item f.

Fire Protection Program.

3)

Specification 6.5.2.8, audits of the following activities shall be performed under the cognizance of the ORC:

item o.

Facility Emergency Plar and implementing procedures, item f.

Facility Security Plan and implomonting procedures, item h.

Facility Fire Protection Program and implementing proceduros.

The administrativo controls for the Fire Protection Program are consistent with the administrative controls for the Security Plan and Emergency

Plan, and are thorofore consistent with the requirements of Generic Letter 88-12.

In ad31 tion to the

above, for License Condition 2.C.5 (Firo Protectio:.

Program),

DLC understands the phrano "implomont and maintain in offect all provisions of the approved firo protection program" to mean that all provisions of the approved fire protection program which (1) portain to NRC requirements, or (2) affect plant safoty or the ability to achiovo and maintain safe shutdown in the ovant of a firo, are required to bo implomonted and maintained.

The reasons for which DLC has established a fire protection program for BVPS-1 are as follows:

NRC regulations Insuranco company guidolinos Industry codes and standards DLC standard practicos Protection of DLC's capital investment

i Beaver VallCy Pow 3r Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Page 4 As a

result, many of the provisions of the fire protection program may not coincide with areas which affect the NRC's review or plant safety.

However, DLC believes that it is beneficial from the standpoints of consistency, efficiency, and effectiveness to include all provisions related to fire protection into one integrated program vs. separate programs, j

The proposed amendment would remove the fire protection requirements from the BV-1 technical specifications based on the guidance' provided in Generic Letters 88-12 and 86-10, and would be consistent with our present program at Unit 2.

If there are any questions, please contact m'f staff.

Very truly yours, j

L h17 D.

Sieber _ _ _

Vice President Nuclear Group Attachment cc:

Mr. J.

Beall, Sr. Reuident Inspector

+

Mr. W. T. Russell, NRC Region I Administrator Mr.

P. Tam, Project Manager Director, Safety Evaluation & Control (VEPCO)

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