ML20009A225
| ML20009A225 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 07/02/1981 |
| From: | Heider L YANKEE ATOMIC ELECTRIC CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| FYR-81-99, GL-81-23, NUDOCS 8107090265 | |
| Download: ML20009A225 (2) | |
Text
YAkKEE ATOM 10 ELECTRIC COMPANY 2.C.2.1 in
_f U1 1671 Wcrcester Road, Framingham, Massachusetts 01701 yyg gy_99 YANKEE
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July 2, 1981
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United States Nuclear Regulatory Commission
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Attention:
Mr. Darrell G. Eisenhut, Director p.
Division of Licensing 9
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Subject:
INPO Plant Specific Evaluation Reports
Dear 'tr. Eisenhut:
Your letter of June 4,1981 to all plants (Generic letter No. 81-23) reqcested that plant specific evaluation reports issued by the Institute of Nuclear Power Operations (INPO) be placed on our Docket. This request appears to establish a precedent that seems to have substantial, unattractive aspects for us.
INPO Audit Reports, like many other detailed reports by outside consultants, are provided to utility management for their own internal use.
We, as do most utilities, frequently use specialized consultants to appraise a particular aspect of our business with the goal of identifying improvements.
Generally, these reports contain recommendations that management evaluates in concert with internal information to formulate or revise policy. Since consultants are expert in their field, their recommendations are given much credence, but are seldom implemented without careful adjustment. Putting detailed reports of this nature on the Docket and in the Public Document Room seems to accomplish nothing other than potentially reduce management prerogative regarding implcmentation. This precedent, therefore, is not one that we wish to establish.
Additionally, it is not clear that providing INPO Evaluation Reports to the staff would enhance staff knowledge of any licensee beyond what is currently available. This is primarily true because of the NRC's own Performance Appraisal Branch (PAB) audits which are essentially duplicative of the INPO efforts, sad in the recent past, have seemed to approximate the INPO audit schedule fairly closely.
If there were no PAB audits, one might argue that some additional information might be contained in INPO evaluations over what is available to the staff. But since there are, at present. '* would O/
seem that all information developed by the PAB audits would be
- nerally
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available within the NRC.
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8107090265 810702 PDR ADOCK 05000029 P
United States Nuclear Regulatory Commission July 2, 1981 Attention: Darrell G. Eisenhut Page 2
- For-all of the foregoing and unless circumstances change such that INPO audits are recognized in lieu of PAB audits, we cannot commit to submitting detailed INPO audit reports on our Docket. Should you have any questions, please contact us.
Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY d
W//-/ewdd L. H. Heider Vice President P
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