ML20100N088
| ML20100N088 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/12/1985 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 1134, NUDOCS 8504180283 | |
| Download: ML20100N088 (4) | |
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TOLEDO EDISON Docket No. 50-346 RCHARD P. CROUSE ve. oresec r*,=ar
. License No. NPF-3' I4191249 5221
- Serial No. 1134 April 12,.1985 Director of Nuclear Reactor Regulation
- Attention:
Mr. John F. Stolz Operating Reactor Branch No.'4 Division of Licensing United States Nuclear Regulatory Conunission Washington, D.C.
20555
Dear Mr. Stolz:
This is in response to your letter dated January 25, 1985 (Log No. 1686) that requested Toledo Edison's response to a questionnaire on Regionaliz-atton. Attachment 1 to this letter is our response as it relates to the Davis-Besse Nuclear Power Station Unit No. 1.
Very truly_yours, v
RPC:RFP:lah cc: DB-l NRC Resident Inspector i
8504180283 850412 PDR ADOCK 05000346
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THE TOLEDO EDISON COMPANY -
EDISON PLAZA 300 MADISON s /ENUE TOLEDO, OHIO 43052
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Dockst'No. 50-346' Licenza No.- NPF-3
-Serial No. 1134 Attachment'l Page 1 T
Survey for Licensees Regarding Regional Review of Licensing Actions i
LThe responses to the following questions are made in the context of the Regional reviews specifically related to Toledo Edisen. The reviews casigned.-by Nuclear Reactor Regulation (NRR) to the Eegion to date have not been.those of significant safety concerns.
J Question 1:
Has the overall safe operation of your facility been enhanced by having selected licensing action technical reviews' conducted in the Region? If so, how?
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Response
oTo date, none of the issues that have been forwarded to the Region for review would have resulted in any significant difference in the overall effect on the safe operation of l
the facility. Therefore, no enhancement in the overall safe operation of the facility has been realized.
Question 2:
Have you been~ generally satisfied with the time response of licensing actions when Regional reviewers are involved?
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Response
Each licensing action is-unique and it is difficult to predict the length of time required to accomplish. However, recognizing that the reviews which have been forwarded for Regional review have not been seen to be of a critical j
nature, timely response has not-been seen as-either a problem or an advantage.
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Question 3:
_Did improved. communications-between your staff and the NRC result from the Regional review process?.
' Response:
.The Regional review process hac not resulted in any overall significant improvement in communications between r
i the NRC and Toledo Edison. _ Prior to regionalization,' the j
NRR Project Manager would coordinate communications through an individual in the utility., This~ insured a mutual 9
' understanding of priorities, importance and actions.
In:
-some cases,~ Regional review activity contacts have been
'made directly with'the utility independent-of either NRC or H
utility coordinator. This has, at times, lead to confusion
- on licensing action priorities, efficiency and requests for additional information.
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I LQuestion'4:
LHas'the Regional review process resulted in fewer' technical disagreements between your staff and the NRC over licensing actions?
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'Dockht Ns. 50-346 Licento No. NPF-3 Serial No. 1134 Page 2
Response
For those items reviewed to date by the Region, there has been no apparent reduction in the. number of techniccl disagreements over licensing actions. Most disagreements associated with technical reviews originate in lack of understanding of the issues involved or the effect of the issues on the specific plant.
In several instances, the Region reviewers do not appear to be as familiar with the plant safety design basis as reviewers in NRK. Additionally on reviews concerning a very limited scope activity, it seems to be a tendency in the Regional case to go beyond the scope of the r9 view requested by NRR. Both of these items tend to result in disagreements during the review, some technical, some administrative.
Question 5:
Have you been generally satisfied with the types of licensing activities being reviewed in the Regions?
Response
Based on the types and significance of the reviews being forwarded to the Region for Davis-Besse, Toledo Edison has not been significantly dissatisfied with the types of licensing activities being reviewed in the Region.
Question 6:
Can you suggest licensing actions that are not being reviewed in the Regions, that in your opinion, should be?
Response
In our opinion, the depth of historical and technical expertise available to NRR as well as the overall under-standing of prioritization needs on both sides makes NRR the more appropriate reviewer for the majority of licensing actions. No additional types of actions are recommended for Regional assignment.
Question 7:
Can you identify any licensing actions that were reviewed in the Regions that, in your opinion, should have been reviewed by Headquarters?
Response
See the response to Question 6.
Question 8:
Has_the Regional review process brought pressures to bear that would not ordinarily be experienced from Headquarters reviews; e.g., enforcement concepts, etc.?.
Response
-TED has seen no evidence that pressures such as enforcement concepts have been brought to bear on Regional reviews. However, la person normally tasked with an enforce-ment orientation has difficulty divorcing those' aspects frem a technical review.
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l Docket N. 50-346' Lic n o No._-NPF-3' Serial No. 1134 Page 3
' Question 9:
Would you say that the overall quality of the licensing review process has improved, stayed the same, or degenerated as a result of Regional involvement?
' Response:
Although Regional activities have not degraded the overall
. quality of the licensing. process, TED believes that the overall quality is maintained better by NRR.- From a documentation aspect, the depth and quality of NRC safety evaluations is noticeably lackirg in the Regional review.
From a coordination concept, the Regional activities have had.a mildly adverse effect en the efficiency of regulatory interactions.
If. Regional assignments continue, these areas should be evaluated for improvement.
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