ML20155H867
| ML20155H867 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/02/1998 |
| From: | Donnellon R CENTERIOR ENERGY |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| RTR-REGGD-XX.XXX 2567, NUDOCS 9811100306 | |
| Download: ML20155H867 (2) | |
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Davis-Besse Nuclear Power Station 5501 North State Route 2 Oak Harbor. Ohio 43449-9760 a
.m Docket Number 50-346 License Number NPF-3 Serial Num'oer 2567 November 2, 1998 Rules and Directives Branch, DAS Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555--0001
Subject:
Comments on Draft Regulatory Guide DG-1069, " Fire Protection Program for Nuclear Power Plants During Decommissioning and Permanent Shutdown" Ladies and Gentlemen:
The NRC is soliciting public comments on NRC Draft Regulatory Guide DG-l%9, " Fire Protection Program for Nuclear Power Plants During Decommissioning and Permanent Shutdown," dated July 1998. Toledo Edison has reviewed the proposed regulatory guide and is submitting the attached comments.
Should you have y questions regarding this matter, please contact Mr. J. L. Freels, Manager - Regu!. sry Affairs, at (419)321-8466.
Very truly yours, M
Robert E. Donnellon Director - Engineering and Services KAS/laj l
Attachment cc:
J. L. Caldwell, Acting Regional Administrator, NRC Region lil I
S. J. Campbell, NRC Region III, DB-1 Senior Resident inspector A. G. Hansen, NRC/NRR DBNPS Project Manager Utility Radiological Safe,ty Board 3, o 9811100306 9811 d O PDR ADOCK 05000346.
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Serial Number 2567 Attachment Pagei Comments to NRC Draft Regulatory Guide DG 1069
" Fire Protection Program for Nuclear Power Plants Durine Decommissioning and Permanent Shutdown"
- 1) Section 3.3.1 - General:
This section recommends plant and contract personnel be trained in the use of fire extinguishers. This requirement is excessive and costly, since there could be more people on site during decommissioning than while the plant is operating. This would result in an unnecessary cost to train plant and contract personnel in the proper use of fire extinguishers. Any fire in the plant should first be reported to the control room by plant and contract personnel. The control room is responsible for assigning specially trained fire brigade members to extinguish the fire.
- 2) Section 3.3.2 - Fire Watch:
As stated above, the fire brigade is responsible for extinguishing plant fires. Plant personnel or contractors performing fire watches who are not involved in hot work do not need to be trained in fighting fires, but rather trained on the prompt reporting of the fire to the control room so that an appropriate response to the situation can be made without delay.
- 3) Appendix B - Spent Fuel Pool Area:
This section recommends suppression and detection systems for spent fuel pool areas.
Due to the large, open nature of these spaces, the design and installation of these types of systems is difficult and expensive while at the same time the benefits are marginal in l
relationship to the cost required to install such systems.
- 4) Appendix B - Radioactive Waste Storace and Accumulation Areas. Includine Temporary Structures:
This section recommends removing wastes on a daily basis. This requirement seems excessive and the paragraph should be changed to read "as the hazard warrants."
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