ML20235E960

Requests Meeting W/Nrc to Discuss Util Fire Protection Program by 871030.Schedule to Establish Full Compliance W/ App R by Sixth Refueling Outage May Be Impaired Without NRC Approval of Outstanding Submittals by 871231

ML20235E960
Person / Time
Site:	Davis Besse
Issue date:	09/21/1987
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
1425, TAC-56864, NUDOCS 8709280348
Download: ML20235E960 (2)

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, - > 1 r .o Docket No. 50-346-USNRd-bs mREDO License No. NFF-3  !

M81 SEP 25 Av 9 39 Serial No. 1425 OONAd) C. SHELTON Vce PreWenty f$cieur (419] E442399 September 21, 1987 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20S55

Subject:

Meeting with NRC Staff Regarding Fire Protection Gentlemen:

In letter dated May 27, 1987 (Serial No. 1361), Toledo Edison stated it l would be pleased to meet with the NRC Staff to discuss the Davis-Besse Fire Protection Program. Additional requests for such a meeting have been subsequently discussed with the NRC Davis-Besse Project Manager, Mr. A. I DeAgazio. However, in each case. Toledo Edison was informed that such a j meeting could not be scheduled due to the unavailability of the NRC reviewer. Toledo Edison appreciates Mr. DeAgazio's efforts and continues to request such a meeting to present the Appendix R compliance schedule, to provide a forum for timely responses to any NRC Staff questions, and to support NRC Staff review of the Davis-Besse Fire Protection Program.

Toledo Edison is committed to the applicable fire protection requirements of Appendix R. An aggressive schedule to implement the necessary physical modifications and changes in its programs and procedures has been established.

As acknowledged 1n NRC letter dated April 9, 1987 (Log No. 2276), Toledo Edison's schedule to establish full compliance with Appendix R is the sixth refueling outage. This compliance schedule, however, may be adversely impacted without NRC approval of the current outstanding Toledo Edison submittals by December 31, 1987.

Toledo Edison has the following three groups of submittals outstanding with the NRC:

1) Appendix R exemption requests submitted i.' letters dated March 6, 1986 (Serial No. 1255) and supplemented by letter dated January 12, 1987 (Serial No. 1327).

2) Submittals dated May 27, 198/ (Serial No. 1361) and July 30, 1987 (Serial No. 1396) regarding the NRC's Request for Additional Information (RAI) dated December 17, 1986 (Log No.

2166).

3) Application for an amendment to the Davis-Besse Fire l'rotection Technical Specifications submitted in letter dated May 20, 1987 (Serial No. 1385).

8709280348 870921 PDR ADOCK 05000346 F PDR THE TULLUU tubuN CUwAm tusum n.AZA 300 MADISON AVENUE TOLEDO, OHlO 43G52 \

Docket No. 50-346 i License No. NPF-3 Serial No. 1425 Page 2 Toledo Edison believes that its exemption requests are similar to those granted by the NRC to other utilities and could be approved by December 31, 1987. Toledo Edison has previously informed the NRC Staff in letters dated November 7, 1986 (Serial No. 1-678) and January 12, 1987 (Serial No.

1327) that this compliance schedule is contingent upon NRC Staff approval of the exemption requests.

l The requested Fire Protection Technical Specification amendment will reduce the number of fire protection penetration seals requiring inapec-tion each interval. The current Technical Specifications require inspection

of all penetration seals separating safety-related equipment every 18 _

months. Such an inspection would involve more than 12,800 penetrations and cost over $250,000.00 to perform. The proposed Technical Specification would reduce the required inspection to 10% of the penetrations separating safe shutdown equipment required in the event of a fire. The reduced '

scope of inspection is based on the Westinghouse Standard Technical Specifications and Technical Specifications previously issued to other nuclear power plants. The next scheduled performance of the current surveillance is February 1988, which coincides with the fifth refueling outage. The planning and scheduling of this surveillance must begin soon in order to define the scope of the outage in light of the constraints of the outage schedule and manpower. The application contained in Serial No.

1385 requested NRC approval of this amendment by December 31, 1987.

The requested meeting would also allow a presentation of the aggressive schedule Toledo Edison has undertaken to implement Appendix R. This presentation would include a sun: mary of those activities to be completed by the fifth and sixth refueling outages, including the December 15, 1987 submittal planned as a follow-up to the NRC's RAI, and the planned Fire Protection Program enhancements. These enhancements are not necessary to comply with Appendix R and are scheduled for completion beyond the sixth refueling outage.

In order to sacisfy the Appendix R compliance schedule and to preclude unwarranted performances of excessive Technical Specification surveillance, Toledo Edison considers that NRC approval of the outstanding submittals is necessary by December 31, 1987. Toledo Edison considers that a meeting will expedite the NRC's review and provide a forum for timely responses to any questions that may arise. Toledo Edison, therefore, requests a meeting with the NRC to discuss its Fire Protection Program by October 30, 1987.

Very tr y yours, j vt b '

MAL: bah cc: DB-1 NRC Resident Inspector A. B. Davis, Regional Administrator

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