ML20136J219

Discusses Plans Re Exemption Requests Provided in 840906 App R Compliance Assessment Rept & Application to Amend License NPF-3 Re Fire Protection Tech Specs.No Further Action on Exemption Request Required.Application Withdrawn

ML20136J219
Person / Time
Site:	Davis Besse
Issue date:	12/10/1985
From:	Williams J TOLEDO EDISON CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
1210, TAC-54259, TAC-56205, TAC-56864, NUDOCS 8601130272
Download: ML20136J219 (2)

Text

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Docket No. 50-346 TOLEDO License No. NPF-3.  !!r!b!ClPd Serial'No.-1210 JOE VVLUAMS, JR.

Sane Vce prescers-Nucieer December 10, 1985 !E E Mr. John F. Stolz, Director PWR Project Directorate No. 6 Division.of PWR Licensing - B United States Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Stolz:

The purpose of this letter.is to discuss Toledo Edisor.'s plans with respect to previous submittals to the NRC. These concern:

.1. The exemption requests provided in the Appendix R Compliance Assessment Report (CAR) (Serial No. 1076) dated September 6, 1984.

2. A Facility Operating License Amendment request (Serial No. 669) dated December 26, 1980 which dealt with several proposed fire protection technical specification modifications for the Davis-Besse Nuclear Power Station Unit No. 1.

Concerning the exemption requests, on September 6, 1984, the Toledo Edison Company (TED) submitted the Appendix R CAR which detailed the Davis-Besse Safe Shutdown Analysis and compliance to the requirements of Sections III.G, J, L and 0 of Appendix R to 10 CFR 50. Each fire area was reviewed for compliance to Appendix R and resolutions were proposed consisting of either plant modifications, procedural modifications or exemption requests to specific Appendix R requirements. TEDS technical evaluation concluded that in certain fire areas, while not meeting the letter of Appendix R, the existing fire protection features met or exceeded the intent of the specific requirement. For these fire protection features, exemptions were requested from the specific Appendix R requirements.

Since that time, however, we have re-evaluated our position relative to Appendix R exemptions based on the following:

1. Ongoing reviews of recent technical guidance (Generic Letter 85-01 and SECY 85-306) developed by the NRC.

2. A more detailed review on resolving noncompliances through physical modifications rather than by exemption request.

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. THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652

1. '* Dock 2t No. 50-346 Licznca No. NPF-3 Serial No. 1210 December 10, 1985 Page 2 In light of these changes, no further action on our pending Appendix R exemption requests is required. The results of our evaluation finaliz-ation are to be provided in a revised exemption request package prior to March 6, 1986. This submittal is consistent with our current commit-ment for providing Revision 1 to the CAR.

With regard to the License Amendment request concerning fire protection technical specifications, on December 26, 1980, TED submitted an applica-tion for Amendment to Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station Unit No. 1 (Serial No. 669). This application requested that Technical Specification sections 3.3.3.8, 4.3.3.8.2, 3/4 7.9.1., 3/4 7.9.2, 3/4 7.9.3, 3/4 7.9.4, and Tables 3.3-14, 3.7-4 and 3.7-5 be revised. We have reexamined our position and feel that it is necessary to further revise our technical specifications to ensure consistency with the existing plant con-figuration and the planned revisions for the CAR and the Fire Hazards Analysis Report (FHAR) which are scheduled for completion by March 6, 1986. We are therefore withdrawing this License Amendmenc request and will provide your office with a revised License Amendment request prior to June 1,1986.

Very truly yours, Mm

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i cc: DB-1 NRC Resident Inspector J. Ulie, NRC Region III}