ML20054L254

Responds to Generic Ltr 82-10, Post-TMI Requirements. Previous Position Re Several Items Modified to Be Consistent w/SECY-82-111

ML20054L254
Person / Time
Site:	Davis Besse
Issue date:	06/30/1982
From:	Crouse R TOLEDO EDISON CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-1.C.1, TASK-2.D.1, TASK-2.K.3.30, TASK-2.K.3.31, TASK-3.A.1.2, TASK-3.A.2.2, TASK-3.D.3.4, TASK-TM 831, A82-470B, GL-82-10, TAC-49582, TAC-49583, NUDOCS 8207070313
Download: ML20054L254 (7)

Text

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%us EDISON Docket No. 50-346 "$$["

License No. NPF-3 " "**S "2 '

A82-470B Serial No. 831 June 30, 1982 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Eisenhut:

Generic Letter 82-10, dated May 5, 1982 (Log No. 981) requested information regarding completion dates and schedules on selected NUREG-0737 TMI-related items. The information as it relates to the Toledo Edison Company and the Davis-Besse nuclear Power Station Unit No. 1 is attached.

Certain of the items as noted in your letter are still under development and require no reply by Toledo Edison at this time. However, other specific items for which a reply is requested appear to be inconsistent with other recent NRC actions. These items are discussed below:

1. Item I.A.I.3.1 " Limit overtime" In Generic Letter 82-10, this item is discussed as if it is on-going with completion due by October 1, 1982. The references given for this item are Generic Letter 82-02, which proposes changes to NUREC-0737 and Regulatory Guide 1.33, and SECY-81-440.

l NRC Inspection Report 81-10, dated June 19, 1981 (Log No. 1-519) identified this item as acceptably completed for the Davis-Besse Nuclear Power Station. As a result of this report, Toledo Edison has considered this NUREG-0737 item as implemented, closed and NRC l

approved.

2. Items III.A.I.2 " Upgraded Emergency Support Facilities" III.A.2.2 "Meteoroloaical Data" l

Your generic 1ctter appears to be in disagreement with the recent policy discussions in the June 14, 1982 meeting, where majority pk THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHlO 43652 8207070313 820630 PDR ADOCK 05000346

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Docket No. 50-346 License No. NPF-3 Serial No. 831 June 30, 1982 Page 2 approval of the Nuclear Regulatory Commission paper SECY-82-111 on the subject of Emergency Response Capabilities was given. In fact, Toledo Edison has modified its previous position on several items to be consistent with the subject SECY paper. These revised positions are reflected in the attachment.

3. Approach to Scheduling SECY-82-111 recommends that certain NUREG-0737 items be better defined to the licensee followed by a plant specific schedule from the licensee which the NRC could use as a basis to ensure timely resolution. Generic Letter 82-10 does not appear to conform to the important policy features of allowing the flexibility of determining what specific actions and schedules are needed at each unique facility. Toledo Edison agrees with the approach of SECY-82-111, and would prefer to handle these issues in a manner consistent with that NRC document. Further discussions on this approach are encouraged in the near future.

Very truly yours, f

l RPC:LDY: lab attachment cc: DB-1 NRC Resident Inspector I

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10 CFR 50.54(f)

SUBMITTAL IN RESPONSE FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. I FACILITY OPERATING LICENSE NO. NPF-3 This letter is submitted in conformance with 10 CFR 50.54(f) in response to Mr. Darrell G. Eisenhut's letter of May 5, 1982. This deals with Post-TMI Requirements (Generic Letter 82-10), Enclosure 1.

By /f/

Vice President, Nuclear Sworn to and subscribed before me this 30th day of June, 1982.

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dLWfbl Notary Public mu CAROL UN; HORST x;ta,,. F:.Un, State of Ohio My Comminion Expires Jr.e 3,1533

ht' KEG-0737 ITEMS LICENSEE RESPONSE.

Toleda Toledo Nt' REG-0 717 Edison E.lison Item Title liesc r ipt i on Sc hedule I.et t e rs S<hedule Remarks I . A. I .L I Limit Over- Revise administrative pro- 11/1/80 12/30/80 #670 Completed Toledo Edison has revised admin-time redures to limit overtime ist rative procedures to limit in ac cordante ht1 REG-073 7. overtime. This item is considere.1 closed by hRC Inspection Report 81-10 dated June 19, 1981 (Lng No. 1-519).

l.A.I.3.2 Hinimum Shift Augment current shift staff- 7/1/82 5/13/82 #RI? Pending Operator Problems with meeting the schedule were ing to conf orm with minimum Licensing Exams identified in nur letter of flay 13. 1982 Crew levels set forth on page 3-9 (Serial No. 817) efforts will continue of NUREG-0737. as identified until compliance is achieved.

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I.C.1 Revise Emer- Revise procedures by next First Refuel- 12/10/80 #670 First Refueling The Anticipated Transient Oper-l gency Pro- refueling outage. ing after 7/9/RI #726 af ter 10/1/82 ating Guidelines (ATOG) pro- j redures 10/1/82 after guideline gram was submitted generically l

l approval (ATOG) by the BW owner group and is cur-I rently under staff review.

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NUREC-0737 ITDtS LICENSEE RESIONSE Toledo Toledo NUREG-0737 Edison Edison item Title Des c r igit i nn Sihedale 1.ctters Schedule Res.e s ks II.D.I.2 RV & SV Test Submit plant specific 4/1/82 7/1/81 #11ti See Remarks Test results are under evaluation j Programs reports on relief and 3/31/82 #R00 regarding plant specific valve l salcty valve program, performance. Toledo E.lison is par-ticipating in the F.lRi IVR safety an.1 relief valve trst program and supports the current INR utilities sc hrilut e on this item. N,.x t submittal is planned July 1 1982.

! ! .11.1.1 Bloc k Valve Submit report of results 7/1/82 See Remarks Toledo Edison is particip.iting Test Program of test program. in the EPHI ivR Safety an.1 Relief Valve Test program an.1 surports the current ISR utilities schedule on this item. Toledo E.lison plans a submittal on July 1, 1982.

i t . k .1. 50 Sit LtiCA Submit plant specific One year 1/30/81 #684 Ona year after Extensive discussions between the NRC Analysis analyses, after staff 11/24/81 #760 staff approval of Staff and B&W Owners Analysis Subcom-approval of mo.fe l mittee have established a proposed mo lel program.

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fiUREG-0,7 37 ITEM _S,I.lCI NSFE RESPt1N'iE To!cito Toledo NL' REC-0737 Eilison Edison

.I t em Ti, t le Descrip. tion . Schedule _  !.e t t e r s Schedule Hemarks ll .k. l. Il Complianic Plant Specific calculations One year 12/.10/80 #670 One year after Extensive discussions hetscen the NRC with after staff staff approval Staf f and P.W Wners Analysis Subcom-10CFR50.46 approval of of mo.let mittee have established a proposed model p r o g r .am .

Ill.A.I.2 Staffing Provide for augmentation 7/1/82 4/21/82 ft-261 Toledo Eilison will meet the coensit-Levels for of statfing 8n accordance 6/23/82 #1-275 enent of Table B-1 as identified in Emergency with Tatle B-1 NURF.C 0654. 6/23/82 #828 Revision 4 of the Emergency Plan.

Situations This has been accepted during the February 8-19, 1982 Site Inspection Review.

til.A.I.2 l'pgrade Emer- Complete modifications. 10/1/82 12/27/79 #571 gency Support 4/3/80 #606 Facilitics 9/29/80 #653

a. Tect.nical Support 5/27/81 #719 Completed a. Center and facilities are Center (TSC) operatlonal.

Og eration Support Center (OSC)

Emergency Operation Facility (EOF) 4 3

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M' REG-PDLITEtlS 1.icmF zt REScosSE Tote.lo Toledo NITdG-0137 E.lison Efison Item Title Desf ript_ ion Schedule I.ctters Sc he.l_u l_e Remarks

b. S.if et y Pa rameter Display 5/27/81 #119 2nd Qu u t er b. SP!15 requirement will follow System ( SI'DS ) of 1981 those reremmen led in SECY82-Ill.

Documents of Sect ion 2 of the NRC Staff recommendations on the requirements for emergency response capabilities will be used as guidance.

Ill.A.2.2 tie t eo ro- Complete ma.lifications. 10/1/82 6/30/81 #124 10/1/82 Toledo Edison will provide its logiial llata meteorological data by its currently installe.1 primary tieteorological Data System. A Class "A" Dose Prediction flodel is being developed for operation by October 1, 1982. No on-site Secon lary tieterological Data Arquisition System will be i ns t a l l e.t.

Ill.D.1.4 Control Room flodif y f acility as identi- Plant 5/28/81 #716 Complete As identified in our Harth 16, 1982 ilihitability ficd by licensee study. Specifir 3/16/82 #796 (Serial No. 798) submittal no facility modifications were identi-ficd or planned by licensee stuly.

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