ML20081C884

Comment Re NRC Proposed Generic Communication Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities. Util Ack NRC Efforts to Reduce Scope of GL 88-20,but Believes That Proposed Changes Still Overly Restrictive

ML20081C884
Person / Time
Site:	Davis Besse
Issue date:	03/03/1995
From:	Stetz J CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
FRN-60FR5734, REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR 2280, 60FR5734-00007, 60FR5734-7, GL-88-20, NUDOCS 9503200045
Download: ML20081C884 (2)

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Toledo, OH 43652-0001 lii5 P 16 IB D 55 Vice President - Nuclear 419-249-2300 Davis-Besse Os RULES ,_.

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to87 l Docket Number 50-346 boFK5734 License Number NPF-3 Serial Number 2280 John Chen March 3, 1995 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Attn.: Chief, Rules Review and Directives Branch

Subject:

Comments Regarding the NRC Proposed Generic Communication Supplement 5 to Generic Letter 88-20, " Individual Plant ,

Examination of External Events (IPEEE) for Severe Accident Vulnerabilities" (60FR5734)

Gentlemen Toledo Edison, a au%idiary of Centerior Energy, is partial owner of and ,

is responsible for operation of the Davis-Besse Nuclear Power Station '

(DBNPS). As a 10 Ch'R Part 50 licensee, Toledo Edison has a vested inter-est in any policies trat the U. S. Nuclear Regulatory Commission (NRC) ,

may adopt which can affect the management and operation of a commercial nuclear power plant.

Toledo Edison has reviewed the NRC proposed Generic Communication Supple-ment 5 to Generic Letter 88-20, " Individual Plant Examination of Exter-nal Events (IPEEE) for Severe Accident Vulnerabilities," (60FR5734).

• Based on this review, Toledo Edison believes that for plants that are implementing the Seismic Qualification Utility Group (SOUG) methodology to resolve Unresolved Safety Issue (USI) A-46, there is no added-cost justification for continuing with the seismic portion of IPEEE. The additional components identified by IPEEE that are not on the SOUG " Safe Shutdown Equipment List (SSEL)" could be included in the SOUG valkdowns.

The SOUG methodology provides reasonable assurance that there is addi-tional margin beyond the licensed seismic event by requiring the site ,

specific ground spectra be enveloped by the SOUG bounding spectra.

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Operating Companies:

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• . .. - Docket Nu:ibar 50-346 Licensa Numb 2r NPF-3 (

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Toledo Edison notified the NRC by letter (Serial Number 2242) on August 25, 1994, of revisions to commitments in the IPEEE effort related to the l DBNPS. Specifically, Toledo Edison has implemented a reduced-scope Seismic Margins Assessment (SMA) as opposed to a focused-scope SMA and extended the IPEEE submittal date to March 1, 1996. Implementation of the focused-scope SMA, as defined by the proposed Supplement 5 to Generic Letter 88-20 would adversely impact the completion schedule, reduce the cost benefit to Toledo Edison of a reduced-scope SMA, and require a further extension to the IPEEE submittal schedule beyond 1996 to include additional information that is not presently a part of the reduced scope program.

Toledo Edison acknowledges the Staff's efforts to reduce the scope of Generic Letter 88-20, but believes that the proposed changes are still overly restrictive. Toledo Edison encourages the NRC Staff to clearly state within Supplement 5 that its requests are not regulatory require-ments and that each licensee may propose the most cost-effective program to satisfy the seismic IPEEE request consistent with the level of seismic hazard at its specific site (s).

If you have questions or require additional information, please contact Mr. Villiam T. O'Connor, Manager - Regulatory Affairs, at (419) 249-2366.

Very truly yours, ,

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cc: L. L. Gundrum, DB-1 NRC/NRR Project Manager J. B. Martin, Regional Administrator, NRC Region III i S. Stasek, DB-1 NRC Senior Resident Inspector '

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