ML20083R725
| ML20083R725 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/16/1984 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| 1042, NUDOCS 8404240273 | |
| Download: ML20083R725 (5) | |
Text
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o Docket No. 50-346 unroc
%s EDISON License No. NPF-3 RCHAnO P. Cm Serial No. 1042 uom name April 16,1984 Mr. Darrell C. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Eisenhut:
The Toledo Edison Company submitted to you on November 23, 1983 (Serial No. 1004), a revised schedule for completing certain evaluations to address the audit findings identified during the Nuclear Regulatory Commission (NRC) 10 CFR 50 Appendix R Audit performed at the Davis-Besse Nuclear Power Station, Unit No. 1 (DB-1). The proposed schedules were found acceptable, per NRC letter from J. F. Stolz, dated January 3, 1984 (TED Log No. 1428).
Since initiation of the Audit Response Program, considerable progress has been made towards the resolution of the findings. This progress has been demonstrated at a series of meetings held with various members of the NRC Staff. Meetings to discuss progress have been held on September 14, 1983, October 4,1983 December 8,1983, January 25, 1984, March 21, 1984, and a workshop on March 23, 1984. The staff has been generally positive in its acceptance of Toledo Edison's approach and progress, to date.
The program status review meetings that have been held thus far have proven to be extremely beneficial.
It is our intent to continue these meetings to assure a satisfactory resolution of the Fire Protection issue at Davis-Besse.
As was discussed at our last program status meeting Toledo Edison is now able to more accurately determine the extent of activities requiring com-pletion prior to the Appendix R Audit Response submittals. The revised schedule for our submittal is included as Attachment 1 to this letter.
Many factors have impacted the Toledo Edison Fire Protection Audit Re-sponse effort. Among these were:
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D:ckst No. 50-346 License No. NPF-3 Serial No. 1042 April 16, 1984 Page 2 1.
Lack of the Fire Protection Audit Inspection Report The Fire Protection Audit Inspection Report has not yet been received by Toledo Edison. Our previous effort and schedules were predicated upon the receipt of the report. While continuing with its aggressive effort, Toledo Edison believes that all work performed should undergo an in depth review against the inspection report prior to submittal to the NRC. This is needed to ensure that the Toledo Edison reviews adequately address the documented audit findings.
Toledo Edison is now at a point on many of the tasks, that the review of our effort to the specific findings should be performed. Upon receipt of the inspection report, the activities on these specific tasks can be reinitiated and completed. The September 1,1984 sub-mittal dates can only be met if inspection report receipt occurs prior to August 1, 1984.
Toledo Edison will submit the Task 1, 2, and 5 results as stated on the attached schedule, without regard to receipt of the inspection report. This can be done because of the generic nature of the Appendix R reassessment.
2.
The NRC Region III Mandated Performance Enhancement Program (PEP)
Toledo Edison is fully involved in the PEP, implemented to improve overall Nuclear Mission performance in regulatory and non-regulatory issues. This program is drawing manpower from all divisions within Toledo Edison. An average of 200 mandays per week is being expended in this effort. This has drawn from the resources available to ad-dress the Audit Response Program and, therefore, has impacted sched-ules. Toledo Edison is committed to this PEP program. As part of the program, the generic nature of the fire protection program de-ficiencies are being addressed.
3.
Specific Technical Program Support Activities Technical issues have evolved through performance of the Audit Response effort that have impacted resources and the previous schedules. These issues have been discussed with your staff and the need to address them has staff concurrence. These issues in-clude:
reevaluation of in-plant combustible loadings, development of detailed documentation packages, and development of the adminis-trative program to ensure compliance to Appendix R throughout plant life.
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Dockst No. 50-346 License No. NPF-3 Serial No. 1042 April 16, 1984 Page 3 4.
Ongoing NRC Cuidance Incorporation Toledo Edison has taken aggressive steps to educate its staff in the appropriate interpretation of Appendix R.
This has occurred through detailed internal document reviews, utility group interactions, ac-tive participation in Fire Protection Seminars and Workshops, and consultant interactions.
However, NRC clarifications have continued to be received by Toledo Edison. These clarifications, which are being factored into the Appendix R reassessment, include IE Notice 84-09. Generic Letter 83-33, and the current Appendix R workshop information.
Toledo Edison is developing an Appendix R program that will be re-sponsive to the latest guidances and interpretations. This reevalu-ation has caused delays, but is in Toledo Edison's interest to ensure that the latest information available is factored into the Toledo Edison response. The revised dates were developed considering the guidance information currently available.
Assuming no further program perturbations Toledo Edison feels it will meet the provided schedules. Toledo Edison will continue its high priority effort on the resolution of all fire protection issues.
Very truly yours, f
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cc: DB-1 NRC Resident Inspector
i D:ckat No. 50-346 License No. NPF-3 Serial No. 1042 April 16, 1984 l
Attachment I t
REVISED TASK COMPLETION SCHEDULE COMPLETION TASK / COMMITMENT ( }TITLE DATES COMMENTS 1 and 2 Appendix R 9/1/84 Total Appendix R Reassessment Evaluation.
3 and 7 Fire Pro-9/1/84 Documenting FRAR, tection Com-FSAR, NFPA, and mitment Re-BTP 9.5-1, Appendix view A Commitments.
(
4 Emergency 1/1/85 Task complete to Lighting original-scope, 1-lighting review I
will require up-dating upon com--
pletion of Tasks I and 2.
5 Associated 9/1/84 Responsive to Circuits NRC Cuidance Analysis (i.e. Generic Letter 81-12 and clarifica-tion letter).
6 One Hour Complete Status will be Barrier Re-provided in re-view sponse to Audit Inspection Report.
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Dockst No. 50-346 License No. NPF-3 Serial No. 1042 April 16, 1984 i
COMPLETION TASK / COMMITMENT ( TITLE DATES COMMENTS 8
Fire Pre-3/1/85 Full Preplan (260
.i plan Re-existing preplans) vision Revisions cannot commence until com-pletion of Taska 1 i
and 2.
Estimate maximum of eleven months to complete 3
revision. Preplans j
1 for rooms containing r
safe shutdown com-ponents will be given priority.
l No Number Damper Complete Discussion will be Assigned Testing provided in response Schedule to Audit Inspection r
l
& Plan Report.
j Development i
i 1
t (1) Task numbers coincide with Tasks identified in the original Audit Response Program submittal (Serial No. 986, dated September 13, 1983)._ Tasks are now grouped as they relate to each other'and will be submitted in that manner. Only Tasks 1, 2, 3, and 5 will be submitted to'the NRC (Reference Restart Safety Evaluation Report, Log 4
l No. 1375, dated September 23, 1983). Status of other tasks will be provided in the TED response.to the Audit Inspection Report.
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