ML19329A870
| ML19329A870 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/09/1975 |
| From: | Roe L TOLEDO EDISON CO. |
| To: | Anthony Giambusso Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8001150763 | |
| Download: ML19329A870 (3) | |
Text
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'o NRC DISTRI3UTION FOR PART 50 DOCKET MA TERIA iTEMPOR ARY FORM)
CONTROL NO:
6352 FILE:
FROM: Toledo Edison DATE OF DOC DATE R EC'D LTR TWX ' RPT OTHER I
Toledo, Ohio 6-9-75 6-11-75 n
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A vc.a,aw June 9, 1975 oc* a ca a-~5 pg 244s> 2es 3242 Docket No.:
50-346
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j@l1 Mr. A. Giambusso, Director m\\ -m
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Division of Reactor Licensing
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Office of Nuclear Reactor Regulation e'
Nuclear Regulatory Commission
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Dear Mr. Giambusso:
Your letter of May 9, 1975 clearly imposes en us the requirement that the "B&W Standardized Technical Specifications" that you are developing will be used as the basis for the issuance of an operating license for the Davis-Besse No. 1 Unit. As stated in our April letter, we will incur an estimated $200,000 additional expenditure as a result of this requirement for which we f ail to find any justification, any advantage to us, or any showing that it will lead to increased safety of operation.
We, however, will continue to cooperate fully with you in the further development of the B&W STS and implementation to this project.
We will continue working with you as a part of the utility group, and also separately, on the specific application to the Davis-Besse No.1 Unit, generally in accordance with the schedules enclosed with your letter. We feel these schedules will not adversely affect the schedule for completion of the licensing effort or training of station operating personnel if reasonably followed with prompt resolution of differences. This also assumes there will be no design changes or backfitting to plant systems and equipment required as a result of the STS review and application to this project.
Your May 9 letter stated that most utility group comments have been resolved.
We, however, do not feel that there has been satisfactory resolution to the majority of our concerns. Many of the NRC responses have been inadequate or unsatisfactory to the utilities and, where this is the case, it will be documented in our further review.
The utility review to this point has concentrated on a general overall review of the sections of the draft STS to identify only the major issues and concerns, leaving the items of concern and details for a later review and resolution. This approach was felt necessary to satisfy the schedule requirements of the lead utilities so that at least the major concerns on all sections of the STS could be reviewed by the whole group prior to
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I Mr. A. Giambusso Page 2 June 9, 1975 imposition of the STS on the lead utilities. This means that further detail comments on all sections will be forthcoming from us.
The full significance of a number of the concerns or issues in the first sections of the STS are not fully apparent until later sections are reviewed in detail where their full applicability comes into focus.
Examples of this are definitions and modes of operation. This, of course, is further cause for detail comments after the first more general review is completed.
We have found in the review that there are Specifications set forth in the STS without full supportive justification in their Bases. This has hampered our review and, in the past, has not been acceptable to the NRC j
for Technical Specifications generated by applicants.
l In view of the imposition of the B&W STS on this project, we assume and consider that Chapter 16 of the FSAR for this project, which contains Technical Specifications submitted in support of our license application pursuant to Sections 50.34 and 30.36 of 10 CFR Part 50, is void and is not a subject of further review by you.
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The schedules included in your May 9 letter are generally satisfactory with a few exceptions and changes, which have been discussed with your Licensing Project Manager.
Yours very truly,
/
i Lowell E. Roe i
Vice President Facilities Development LER.r Copies: Donald H. Hauser, Esquire Gerald Charnoff, Esquire Leslie Henry, Esquire 1
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