ML19282C206

Discusses Forthcoming Application for Amend to License NPF-3 Incorporating Nrc'S Radiological Environ Tech Specs (RETS) Into License.Concludes Amend Is Exempt from Fees.Forwards Safety Evaluation.Tech Spec Changes & Affidavit Encl

ML19282C206
Person / Time
Site:	Davis Besse
Issue date:	03/16/1979
From:	Roe L TOLEDO EDISON CO.
To:	Reid R Office of Nuclear Reactor Regulation
Shared Package
ML19282C207	List: ML19282C206 ML19329D800 ML19329D801 ML19329D802
References
NUDOCS 7903210270
Download: ML19282C206 (2)

Text

TOLEDO

%en EDISON LOWELL E. ROE Docket No. 50-346 v1. w-.4.m License No. NPF-3 """

Serial No. 488 March 16, 1979 Director cf Nuclear Reactor Regulation Attention: Mr. Robert Reid, Chief Opo. rating Reactors Branch No. 4 Division of Operating Reactors United States Nuclear Regulatory Ccamission Washington, D.C. 20555

References:

(a) Letter from D. B. Vassallo, Assistant Director for Light Water Reactors, USNRC, to All Pressurized Water Reactor Licansees, dated July 10, 1978 (b) Letter frco B. K. Crimes, Assistant Director for Engineering and Projects, USNRC, to All Pressurized Water Reacter Licensees, dated November 15, 1978

Dear Mr. Reid:

Under separate cover, we are transmitting three (3) original and f orty (40) conformed copies of an Application for Amendment to Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Staticn Unit No. 1.

The proposed change specifically reflects the Davis-Besse Nuclear Power Statian Unit 1 design. In response to references (a) and (b) both Appendices A and B to the current Technical Specifications have been reorganiced. The enciesed pages identify the changes and additions proposed to incorporate the USNRC's Radiological Environmental Technical Specifications (REIS) into Facility Operating License No. NPF-3. The Toledo Edison Company reviewed the proposed versions of the NRC RETS in the development of this Technical Specification change. The NRC proposals were considered or revisions to current Technical Specifications that would affect greatly the Station's planned cperation by dictating limiting condi tions that are in excess of those needed to ensure cc=pliance with regulatory requirements. In times of increasing attention to availability and reliability of energy produ ing systems, it is wholly cuc of context to impose requirements which are counterproductive to incentives which provide flexibility for operating contingencies in their designs. This finalized Technical Specification change is tailored specifically to Davis-Besse Nuclear Power S tation Unit 1. It represents Toledo Edison's incorpora-tion of the radiological monitoring, evaluation and reporting required by 10 gh

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TfiE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 7 9 0 3 210 21t>

Page 2 CFR parts 20 and 50. Guidance from recent revisions of NUREG-0472 beyond that of regulatory requirements is considered here only where it previded added Station monitoring flexibility.

Additionally, Toledo Edison sees no benefit or requirement in expanding the effort associated with approval of station procedures, operating manuals and programs in this one area, to agencies beyond the current administrative review associated with similar documents in all other areas of facility opera-tion. The regulatory system already has, and uses, mechanisms of the Office of Inspection and Enforcement to assure licensees meet their commitments for facility operation through the use of approved programs and procedures.

Therefore, no such documents shall be submitted to the Office of Reactor Regulation for pre-approval. It is, however, recognized that there is a benefit in the initial review of this Technical Specification change to pro-vide the Station's Offsite Dose Calculation Manual for reference purposes.

This will be submitted within 60 days.

The proposed change does not constitute an unreviewed safety question. The Toledo Edison Station Review Board and Company Nuclear Board have reviewed this change.

These changes will be incorporated into the Davis-Besse Nuclear Power Station Unit No. 1 Technical Specifications 90 days af ter approval by the Commission, but in no case before December 2, 1979.

Fee Determination: The major portion of the proposed change as set forth herein is an extension of the 10 CFR Part 50, Appendix I design study submitted to the USNRC on June 4, 1976. This submittal provided at the NRC's request, references (a) and (b), revises entirely an already filed submittal of September 20, 1976 (Serial No. 120) proposing Technical Specification to fulfill the requirements of Appendix 1. We conclude therefore, that this A=endment is exempt from any fees defined in 10 CFR Part 170.12(c) since fees were not applicable when the requirements put forth by Appendix I to 10 CFR Part 50 became effective, and since review of the previously submitted information has been delayed by the USNRC pending development of revised guidance issued in July, 1978 (reference a).

Yours very truly,

- W u

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APPLICATION FOR AMENDMENT TO LICENSE NO. NFF-3 FOR .

DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Enclosed are forty-three (43) copies of the requested changes to the Davis-Besse Nuclear Power Station Unit No. 1 Technical Specifications, Appendix A and B to Facility Operating License No. NPF-3, together with the Safety Evaluation for the requested change.

Byff 11 s "

07/9 '

General Sfiperintendent, Power Engineering and Construction F6r- Lowell E. Roe Vice. President, Facilities Development Sworn to and subscribed before me this sixteenth day of March, 1979.

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i m& J FRED W. GERMAIN Notary Public - State of Ohio My Commission Expires Oct. 30,1982