ML20082F166

Requests Expeditious Issuance of Amend to License NPF-3,per 801223 Application & 810710 Supplemental Submittal Re Fire Barrier Penetrations,Tech Spec (Item 6)

ML20082F166
Person / Time
Site:	Davis Besse
Issue date:	11/22/1983
From:	Crouse R TOLEDO EDISON CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
1006, TAC-51387, TAC-54259, NUDOCS 8311280452
Download: ML20082F166 (2)

Text

--

i TOLEDO Docket No. 50-346 License No. NPF-3 b$Ncm e+a.c Serial No. 1006 "'8'258-5 8' November 22, 1983 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz Operating Reactor Branch No. 4 Division of Operating Reactors United States Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Stolz:

This letter is to request issuance of a license amenduent contained in our July 10, 1981 (Serial No. 731) submittal. Item 6 of that request concerns Fire Barrier Fenetrations as the Technical Specifications relate to the Davis-Besse Nuclear Power Station Unit No. 1 (DB-1).

Toledo Edison was requested by Mr. R. W. Reid on September 23, 1980 (Log No. 609) to revise its Technical Specifications for Fire Protection to conform with the Standard Technical Specification. On December 23, 1980 (Serial No. 669), Toledo Edison submitted an amendment request for Fire Protection in accordance with Mr. Reid's letter. Additionally, on July 10,1981 (Serial No. 731) we submitted a supplement to our December 26, 1980 amendment request containing Limiting Conditions for Operation for Fire Barrier Penetrations.

During the week of July 25-29, 1983 an Audit of Fire Protection (10 CFR 50 Appendix R) was conducted at DB-1. As a result of this audit, several areas of concern has been identified which require establishment of continuous fire watches. Currently 30 persons per day are required to maintain the continuous fire watch at a cost of greater than $50,000 per month. This requires considerably more manpower and resource allocation than would be necessary to maintain a reving fire watch which would verify the operability of the fire detection system on a regular basis.

The current specification addressing Fire Barriers requires establishment of a continuous fire watch when any barrier is declared non-functional.

Other courses of action exist that can be taken to mitigate the consequences of a fire and that will require less expenditure of manpower costs. The requirement to establish a roving fire watch and verify the operability of fire detection system or establish a continuous fire watch assures that a fire in the affected area is detected early j enough to initiate protection actions.

h y

THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 F311280452 831122 PDR ADOCK 05000346 P PDR

l Dock 2t N3. 50-346 s- Licr.n32 Ns. NPF-3 Serial'No. 1006 November 22, 1983

~Page 2

. Toledo Edison believes that the. resources that are necessary to provide compensatory actions under the proposed amendment request, provide an adequate margin of safety to ensure the public health and safety.

Therefore, we request that our July 10, 1981 (Serial No. 731) amendment request item 6, Fire Barrier Penetration,-be issued expeditiously.

Very truly yours, RPC: GAB:lah cc: DB-1 NRC Resident Inspector State of Ohio

)

- _ _ _ _ _ - _ _ _ _ _ _ - _ ,