ML20033F002

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Responds to Generic Ltr 90-01 Re NRC Regulatory Impact Survey.Informs of Concerns on Impact of Team Insps on Licensees & Licensing Process
ML20033F002
Person / Time
Site: Maine Yankee
Issue date: 03/06/1990
From: Nichols S
Maine Yankee
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-90-01, GL-90-1, MN-90-24, SEN-90-46, NUDOCS 9003150244
Download: ML20033F002 (14)


Text

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MaineYankee:

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EDISON DRIVE e AUGUSTA, MAINE 04336 * (205 6224B68 I

March 6, 1990 MN-90-24 SEN-90-46 I

UNITED STATES NUCLEAR REGULATORY COMMISSION

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Attention: Document Control Desk Washington, DC 20055

References:

(a)

License No. DPR-36 (Docket No. 50 309)

_l (b)

USNRC Letter to Licensees dated January 18, 1990, Request for Voluntary Participation in NRC Regulatory Impact Survey

'(Generic Letter 90-01)

(c)

Institute of Nuclear Power Operations Letter to Maine Yankee dated February 8, 1990 (d)

NUMARC letter to NUMARC Board of Directors dated February 16, 1990

Subject:

Response to Generic letter 90-01, NRC Regulatory impact Survey Gentlemen:

j Enclosed please find completed Questionnaire Sheets in ri..ponse to Reference (b). As suggested by INP0 and NUMARC, we have not included INPO assist visits or self-initiated self-assessment-activities.

We are pleased with the NRC's desire to assess the impact they and others are having on individual licensees and their management. One area we are concerned with is the impact team inspections are having on licensees and their impact on the licensing process.

Impact is particularly heavy in evolving areas where generic. guidance has not progressed at the same pace as regulatory expectations -

Examples may be recent procurement inspections and SSFIs conducted throughout the industry. We recognize that important generic issues are being raised in these areas; however, we do not believe the vehicle for promoting.those issues is the inspection process unless the NRC's expectations have been communicated on the docket to the licensees beforehand.

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- ' UNITED STATES NUCLEAR REGULATORY COMMISSION MN-90-24 Attentione Document-Control Desk-Page two I

6 We appreciate the opportunity to participate in this s::vey. The G'

questionnaire sheets were compiled by Maine Yankee's officers and managers. -Our section-heads and supervisors typically average about the same degree or more involvement in regulatory matters as the managers. Should you have any questions, please' contact the undersigned.

Very trul rs,

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g S. E. Nichols Licensing Section Head SEN:SJJ-Attachments c:

Mr. William T. Russell' Mr. Eric J. Leeds Mr. Cornelius F. Holden NUMARC l '

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- SEN9046.LTR

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Completed

- NRC Regulatory Impact Survey Questionnaire Sheets for Maine Yankee Atomic Power Company 1 - NRC Team Inspections 6 - OSHA 2 - Other NRC Resident, 7 - 00T.

Regional and Headquarters 8 - State / Local Authorities inspections / audits 9 - NRC-Required QA Audits 3 - INP0 Evaluations-10 - Other Self-Assessments 4 - Insurers (ANI) 11 - Other 5 - EPA

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Maine Yankee Docket 50-309 Response to GL 90-01

, of 11 NRC Reaulatory impact Survey Ouestionnaire Sheet 1

1.

Type of inspection, audit or evaluation:

NRC Team Insoections.

2.

Based on ectual experience over the past several years, about how often is this activity conducted?

Four times per year.

3.

Operations / Construction areas covered:

NRC conducts (per aeneric letter.

_ descriptions need not be provided for NRC inspections).

4.

Extent of the activity (how many people, for how long): NRC team insoections vary in composition from three to eleven inspectors and in duration from three days to three weeks.

5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to.

the activity described in Item #1.

(All times are hours.)

a.

Plant Department Heads 252 (number involved) 3 b.-

Plant Manager 20' c.

Corporate Department Heads 1764 (number involved) 8 d.-

Corporate Vice Presidents 663 (number involved) 4 e.

' Chief Nuclear Officer 30 90-01.LTR

2 of 11 NRC Reaulatory Imoact Survey Qqgitionnaire Sheet 1.

Type of inspection, audit or evaluation: Other NRC Resident. Reaional and Headauarters Insoections/ Audits.

2.

Based on actual experience over the past several years, about how often is

- this activity r onducted? Resident inspection essentially onaoina: recional or headauarters insoection about once oer month: NRC audits about once every three months: other activities (e.a. Commissioner visit) sooradic.

3.

Operations / Construction areas covered:

NRC conducts (per Generic letter.

descriptions need not be provided for NRC insoections and audits).

- 4.

Extent of the activity (how many people, for how long): Resident Insoections-l

- two inspectors. essentially onaoina.

Reaional or headauarters inspections-1H one to two oeoole. 4-5 days. Audits-one to four people. one to three days.

L 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

(All times are hours.)

a; Plant Department Heads 350 (number involved) 3 b.

Plant Manager _lqq_

c.

Corporate Department Heads 760 (number involved) 8 d.

Corporate Vice Presidents 227 (number involved) 3 e.

Chief Nuclear Officer __1Q_

4 90-01. LTR

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e 3'

3 of 11 NRC Reculatory Impact Survey Ouestionnaire Sheet i

1.

Type of inspection, audit or evaluation:

INP0 Evaluations 2.

Based oi actual-experience over the past several years, about how often is this activity conducted?_Qnce oer every 18 months.

'[.

3.-

Operations / Construction. areas covered: INP0 conducts (Der Generic letter.

descriptions need not be orovided for INP0 evaluations).

4.

Extent of the activity (how many people, for how long):

Routine INP0 i

Evaluations.

i l

Approximate percentage of total time (on an annual basis) which the following 5.-

i

- managers must spend-in-direct involvement before,' during,- and in response to the activity described in' Item #1.

(All times are hours.)

j

- a.

Plant Department Heads 296 (number. involved) 3 j

b.

M ant Manager 40 c..

Corporate Department Heads 426 (number involved) 8 d.

Corporate Vice Presidents 101 (numberinvolved) 4 i

e.

Chief Nuclear Officer 20 i

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,90-01.LTR

m 4 of 11 NRC Reaulatory Imoact Survey

)

Questionnaire Sheet 1.

Type of inspection, audit or evaluation:

Insurers (ANI)

' 2.

Based on actual experience over the past soveral years, about how often is -

this activity conducted? Once ocr month.

3.

Operations / Construction areas covered:

Liability (aeneral plant). Fire Protection. Pressure Systems and Machinery. Weld Inspections 4.

Extent of the activity (how many people, for how long):

One person for each area. averaaina about one-th1rd man-year on site.

5; Approximate percentage of total time (on an annual basis) which the following managers must spend in direct-involvement before, during, and in response to-

'the activity described.in Item #1.

(All times are hours.)

a.

. Plant Department Heads _ 43 _

(number involved) 3 b.

Plant Manager-6 c.

Corporate Department Heads 60 (number' involved) 5 d.

Corporate Vice Presidents 22 (number involved) 2 e.-

Chief Nuclear Officer 10

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90-01.LTR

t 5 of 11 t

NRC Reaulatory Impact Survey Ouestionnaire Sheet e

1.

Type of inspection, audit or evaluation:

EPA 2.

. Based on actual experience over the past several years, about how often is this activity conducted? Not sianificant.

3.

Operations / Construction areas covered: N/A 4.

Extent of the activity (how many people, for how long):_ N/A 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to-the activity-described in Item #1.

(All times are hours.)

.a.

Plant Department Heads 0

(number involved) 0 b.

Plant Manager 0

c.

Corporate Department Heads

-4 (number involved) 1 d.

Corporate Vice Presidents 22 (number involved) 2 e.

Chief Nuclear Officer 0-a y

I-390-01.LTR-

6 of 11 NRC Reaulalgry impact Survey Questionnaire Sheet

- 1.

Type of inspection, audit or evaluation: OSHA 2.-

Based on actual experience over the past several years, about how often is this activity conducted? Not sianificant.

3.

Operations / Construction areas covered:

N/A 4.

Extent of the activity (how many people, for how long): N/A 5.-

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

(All_ times are hours.)

a.

Plant Department Heads 0

(number involved) 0 b.

Plant Manager 0

c.

Corporate Department Heads 24 (numberinvolved)'

-2 d.

Corporate Vice Presidents __13_

(number involved) 2 e.

Chief Nuclear Officer 0

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4 7 of 11 NRC Reaulatory Impact Survey j

Ouestionnaire Sheet J

l 1

1.-

Type of inspection, audit or evaluation:

00T l

2.

Based on actual experience over the past several years, about how often is this activity conducted? Not observed.

3.

Operations / Construction areas covered:

N/A 4.

Extent of the activity (how many people, for how long): N/A 5.

' Approximate percentage of total. time (on an annual basis) which the following

- managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

(All times are hours.)

a.-

. Plant Department Heads 0

(number involved) 0 b.

Plant Manager 0

c.. ' Corporate Department Heads 0

(number involved)-

O d.

Corporate Vice Presidents 2

(number involved) 1

- e.

Chief Nuclear Officer 0

, 01.LTR

j 8 of 11 1

NRC Reaulatory Impact Survey Ouestionnaire Sheet 1.

Type of inspection, audit or evaluation:

State / Local Authorities 2.

Based on actual experience over the past several years, about how often is this activity conducted?_ State Nuclear Inspector-Onsite essentially full-i time.

No periodicity for other state / local authorities.

2.

E L

.3.

Operations / Construction areas covered: State Nuclear Inspector-Primarily deals ~ with radiation orotection activities. Other state activities orimarily environmentally related (radioloaical or chemical releases).

, s 4.

Extent of the activity (how many people, for how.long):

State Nuclear-Inspector-0ne oorson essentially full-time.

Other state activities-1 to 3 people. - half-man-day each time.

5.

Approximate percentage of total ~ time (on an. annual basis) which the following managers must. spend in direct involvement before,-during, and in response to the activity described in Item #1.

(All times are hours.)

a.

Plant Department Heads 82 (number involved) 3_

l L

b.

Plant Manager 135 lc..

Corporate Department Heads 80 (number involved) 3 1

i d.

Corporate Vice Presidents 255 (number involved) 3 e.

Chief Nuclear Officer 30 l

D 190,01.LTR s

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i 9 of 11 NRC Reaulatory Impact Survey Questionnaire Sheet

.1.

Type of inspection, audit or evaluation: NRC-Reouired 0A Audits 2.

Based on actual experience over the past several years, about how often is this activity conducted? Eiahteen oer year.

3.

Operations / Construction areas covered:

(Per Generic letter, descriptions l

need not be provided for NRC-reauired 0A audits.)

_4.

Extent of the activity (how many people, for how long): Three oeople one week each audit.

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5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

(All times are hours.)

a.

Plant Department Heads 366 (number involved) 3 b,

Plant Manager 30 c.

Corporate Department Heads 418 (number involved) 8 d.

Corporate Vice Presidents 141 (number involved) 4 e.

Chief Nuclear Officer 20 2

90 01.LTR.

q 10 of 11 j

H_RC Reaulatory impact Survey Questionnaire Sheet i

1.

Type of inspection, audit or evaluation: Other Self-Assessments.

2.

Based on actual experience over the past several years, about how often is this activity conducted? Onaoina.

3.

-Operations / Construction areas covered:

Ouality Proarams Department oerforms about 120 evaluations of specific Company activities per year.

4.

Extent of the activity (how many people. for how long): Ouality Proarams Department Evaluations-one oerson. four days each.

5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement 5;f~ r ocring, and in response to the activity described in Item #1.

(All ti.*

nours.)

a.

Plant Department Heads 257 (number involved) 3_

b.

Plant Manager 30 c.

Corporate Department Heads 290 (number involved) 5-d.

Corporate Vice Presidents 230 (numberinvolved) 3 e.

Chief Nuclear Officer 30 90-01.LTR

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11 of 11 NRC Reaulatory impact Survey Questionnaire Sheet 1.

Type of inspection, audit or evaluation: Other

^

Based on actual experience over the past several years, about how often is 2.:

t.his activity conducted? Annually.' recently

-3.

Operations / Construction areas covered:

Federal Emeraency Manaaement Aaency (FEMA) - Offsite emeraency Dlannina 4.

Extent of the activity (how many people, for how long):

Three people. two days 5.

Approximate percentage of total time (on an annual basis) which the following managers.must spend in direct involvement before, during, and in response to.

the-activity described in Item #1.

(All times are' hours.)

^

.4

a..

Plant Department Heads 0

(numberinvolved) 0 i

b.

Plant' Manager 30 L

c.

Corporate Department Heads 20 (number involved) 1 d.

Corporate Vice Pres! dents 0

(number involved) 0 e.

Chief Nuclear Officer 0

=

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