ML20100G424
| ML20100G424 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/03/1985 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 1137, NUDOCS 8504080242 | |
| Download: ML20100G424 (2) | |
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Docket No. 50-346' y,,gg License No. NPF-3 Serial No. 1137 RCHARD P. CROUSE Vrm Presdert Nuder April 3, 1985 gisi a494aai Director of Nuclear Reactor Regulation
. Attention:
Mr. John F. Stolz Operating Reactor Branch No. 4 Division of Licensing United States Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Stolz:
On' September 6, 1984, (Serial No. 1076), the Toledo Edison Company (TED) submitted the Appendix R Compliance Assessment Report (CAR). This report documented the level of compliance of the Davis-Besse Nuclear Power Station Unit No. 1 (DB-1) to the requirements of 10 CFR 50 Appendix R.
Additionally within that report, plant modifications were proposed to bring the plant into compliance to the regulations.
With regard to those proposed modifications, within Serial No. 1076, it was stated that TED intends to prioritize the proposed modifications and revise the Summary Level Planning Worksheet to show a realistic schedule for completing the proposed modifications. The intent of this letter is to discuss the factors that have delayed the modification prioritization efforts and to provide a revised date that the prioritized modification schedule can be forwarded to you.
The original schedule for completing modification prioritization was based
, upon two factors: 1) the completion of the modification conceptual design for the "most important to nuclear safety" modifications; and 2) the prioritization of all proposed modifications through the use of a Davis-Besse specific, Fire Risk Assessment. Delays have occurred in both of these activities. The primary reasons for these delays are itemized below.
1.
The numerous technical issues requiring immediate attention during the 1984-1985 refueling outage necessitated the temporary shift of manpower to support those activities.
2.
The resulting lack of manpower has impacted the conceptual design development effort in addition to the in-house technical review of the draft Fire Risk Assessment.
3.
While. conceptual design activity continues to receive high priority attention, the on-going. Fire Protection resolution effort requires a DR ADOC
.F THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 iO
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t Liccnzo No, NPF-3' 1 Serial.No.-1137 April 3, 1985 Page 2-
.significant. amount of resources. These activities include but are
-not limited to:
Continued Fire Protection analyses Plant walkdowns Fire Protection procedures revision Performance Enhancement Program (PEP) Fire Protection Action Plan. support 4.'
-A. study of modification alternatives and the determination of the full acceptability of the final proposed modification alternatives j
has.taken longer than anticipated.
While this modification prioritization activity is proceeding somewhat slower than expected. Toledo Edison is making no change to the commitment 3
of achieving full compliance to Appendix R within three refueling cycles, in order of the most significant fixes per our ILSP process, defined in Serial No. 1043; dated July 16, 1984.
1 Based upon the current summary level schedule and work progress, a realistic 4
implementation schedule for modifications to be completed through the end of 1986 will be provided to you no later than September 27, 1985. We feel that.this is reasonable considering the time. required to develop detailed i
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schedules under our Inte' grated Living Schedule Program (ILSP) schedule and the relative significance of_the other Davis-Besse modification and programmatic issues competing for-resources.
As discussed with members of the NRC Staff, detailed implementation j.
schedules'for major ILSP projects are not developed until well into the design process.. Since this is still 6-12 months away on some individual modifications that could be completed by the end of 1986, a realistic.
i schedule is not yet available..
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As_part of.the continuing ILSP schedule revision and statusing process, i
the NRC will be updated on the fire protection project on a semi-annual
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basis.
In an; effort to reach an agreement as to the-acceptability of the Toledo Edison Fire Protection. resolution program,-Toledo Edison would support-
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a meeting with appropriate members of the NRC Staff..We would appreciate the l
opportunity.to discuss our' progress. and' demonstrate our commitment to the e
problem resolution.
My staff looks forward to continued interaction with you on this high-priority issue.
LVery truly yours,.
fO
.RPC:JSH DBI:lah ice: DB-1 NRC Resident Inspector i
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