ML20035C664
| ML20035C664 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 03/26/1993 |
| From: | Thayer J YANKEE ATOMIC ELECTRIC CO. |
| To: | Gillespie F NRC - REGULATORY REVIEW GROUP |
| References | |
| FYC-93-005, FYC-93-5, SPS-93-029, SPS-93-29, NUDOCS 9304080269 | |
| Download: ML20035C664 (3) | |
Text
HAjl-29-S3 MON 16:07 YANKEE ATOMIC X'6731
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PpE relep*rone (502) 7794711 YANKEEATOMIC ELECTRIC COMPANY m.
560 Main Street. Boiton, Massachusetts 01740-1398 Merch 26, 1993 s
FYC 93 005 JAY K. THAYER g
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Mr. Frank T. Gillespie. Chairman Regulatory Review Group Office of the Executive Director Operations U.S. Nuclear Regulatory Commission i
Washington, DC 20555
Subject:
Request for Comments Concerning Draft Material Issued by.the l
Regulatory Review Group (SBFR13808)
References:
(1)
NRC Program for Elimination of Requirements Marginal to Safety: Public Workshop (5BFR6196).
(2)
Letter:
J. Colvin. President and CEO. NUMARC to I. Selin. Chairman. NRC. dated December 21, 1992 (With Attachments).
Dear Mr. Gillespie:
Yankee Atomic Electric Company appreciates the opportunity to comment on the subject Federal Register Notice.
Yankee is the owner of the nuclear. power plant in Rowe, Massachusetts and our Nuclear Services Division also provides l
1 engineering licensing services to other nuclear power plants in the United' States.
Yankee has been specifically charged by our sponsors to aggressively ni pursue revisions to the entire regulatory framework as well as relaxation of 7
specific requirements, many of 1:hich have been characterized by References 1 and 2 as unnecessarily burcensome.
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These comments are intended to be responsive to the subject request
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which indicated a March 22nd due date. Unfortunately. the information package was not available in the public document room until March 23rd. We'have undertaken a quick review of the material in order to attempt to be responsive. We echo the comments of NUMARC in that we agree revisions to unnecessarily prescriptive.or redundant requirements and guidance can result in increased plant performance while maintaining, or even improving overall i
plant safety.
It is imperative that regulations and implementation practices that go beyond those required for. adequate public protection be identified and corrected.
Excessive regulation can no longer be tolerated as just another cost of operating nuclear plants.
The draft material developed to date appears very encouraging.
The Regulatory Review Group (RRG) has clearly identified major areas of the p
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1 Mr. Frank T. Gillespie, Chairman March 26, 1993 Page 2
-regulations and their implementation which should be revised.
Although our perception of-the details differs in soge cases (e.g., whether or not an attempt at a graded approach currently exists for procurement).-the conclusions and recommendation of the group appear "right On".
One of the most profound observations by your group is the statement
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contained in the section entitled " APPARENT INCONSISTENCIES IN THE REGULATIONS WITH REGARD TO THE. METHOD IN WHICH CERTAIN REGULATED ACTIVITIES ARE PLACED LNDER LICENSEE CONTROL."
In that write-up the RRG points out with respect to a licensee commitment:
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... we believe that the commitment is to the basit.
articulation of the requirement and not to the method by which the licensee initially stated that the commitment would be met..... on occasion licensees have held to their methods vice their commitments."
a This statement highlights the essence of a performance-based regulatory system and at the same time the major barrier to achieving it.
As stated by the RRG
... the differentiation between the commitment to it [a requirement] and the method of carrying out this commitment has been difficult to separate for reviewers."
Removal of the confusion between a commitment to comply with a requirement and the individual licensee prescription as to how compliance is to be achieved should become a fundamental attribute of any initiative to improve the regulatory system.
This necessarily brings up a second point.
It is nard to discern from e
the draft documentation any notien of hcw implementation of the good ideas being developed will take place. Without a clear plan to cet results the meaningfulness of the efforts by the RRG could be.vanishingly small.
- Further, there is no specific mention of tht. regulatory initiative presented in the letter to Chairman Selin (Reference 2).
Items identified as Attachments I
_l through 8 of that letter are carefully packaged with sufficient actual data to
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allow implementation of the corrections recommended by each of them without further study. These should.be acknowledged as clear first steps and other thanges being developed should follow closely behind.
We stand ready to assist in the implementation of improvements in any t
way possible.
Very truly yours.
f t
J
. Thayer ice President and DWE/dhm Manager of Operations
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MAR-292@3 MON 16:06 YANKEE ATOMIC X 6731 P,01
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