ML20035H316
| ML20035H316 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, Millstone File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 04/23/1993 |
| From: | Opeka J CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC |
| References | |
| B14457, NUDOCS 9305040194 | |
| Download: ML20035H316 (5) | |
Text
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-r UTILITIES cenerei omee.. seen suee:, Bernn. Conn cucui J
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P.o. Box 270 HARTFORD. CONNECTICUT 06141-0270
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April 23, 1993 Docket Nos. 50-213 1
50-245 50-336 50-423 B1445'7 Re:
Proposed Generic Letter Chief, Rules and Directives Review Branch U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos.
1, 2,
and 3 Comments on Proposed Generic Letter Regarding Availability and Adecuacy of Desian Basis Information The purpose of this letter is to provide the NRC with comments from -
Connecticut Yankee Atomic Power Company (CYAPCO) and Northea st.
Nuclear Energy Company (NNECO) on the proposed Generic Letter regarding the Availability and Adequacy of Design Basis Information as requested by the Federal Register, Volume 58, Number 55, Page 15885, March 24, 1993.
On. behalf of the Haddam Neck Plant and Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3, CYAPCO and NNECO hereby provide, as Attachment 1,
comments on the regulatory and technical aspects regarding the proposed Generic Letter.
We encourage the NRC practice of publishing draft Generic Letters for public comment.
We also endorse the comments provided by NUMARC letter dated April 2, 1993.'"
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W.
H.
Rasin letter to D.
L.
- Meyer, U.S.
Nuclear Regulatory Commission,
" Comments on NRC Draft Generic
- Letter, Availability _and Adequacy of Design-Basis Information," dated April 2, 1993.
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- Chief, B14457/ Page 2 April 23, 1993
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i We hope you find these comments helpful, and we appreciate the opportunity to participate in this process.
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l Very truly yours, l
l CONNECTICUT YANKEE ATOMIC POWER COMPANY ~
NORTHEAST NUCLEAR ENERGY COMPANY l
A/
J. F.(Ojeka O
Executive Vice President cc:
T.
T. Martin, Region I Administrator A.
B. Wang, NRC Project Manager, Haddam Neck Plant J.
W. Andersen, NRC Acting Project Manager, Millstone Unit j
No. 1 G.
S. Vissing, NRC Project Manager,-Millstone Unit No. 2 V.
L. Rooney, NRC Project Manager, Millstone-Unit No. 3 D. H.
Jaffe, NRC Project Manager, Millstone Station
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P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos.
1, 2,
and 3 W.
J. Raymond, Senior Resident Inspector, Haddam Neck Plant i
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
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Docket Nos. 50-213' 4
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Haddam Neck Plant Millstone Nuclear Power Station',-Unit Nos.
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l Chief, Rules and Directives Review Branch l
B14457/ Attachment 1/ Page 1 l
April 23, 1993 i
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i Haddam Neck Plant j
Millstone Nuclear Power Station, Unit Nos, 1,
2, and 3 Comments on Proposed Generic Letter Regarding i
Availability and Adecuacy of Desian Basis Information I
i Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast-j Nuclear Energy Company (NNECO), on behalf of the Haddam Neck Plant i
and Millstone Nuclear Power Station, Unit Nos.1, 2, and 3, provide l
the following comments on the regulatory and technical aspects regarding the proposed Generic Letter.
j l
Reculatory Aspect s
'i CYAPCO and NNECO believe that the subject of design basis control programs in the nuclear industry has received sufficient attention, j
has been properly acted on by the vast majority of nuclear j
utilities, and therefore need not be subjected to any regulatory J
processes.
The NRC surveyed an appropriate number of utilities in-
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preparation of the issuance of NUREG-1397 " An Assessment of Design Control Practices and Design Reconstitution Programs in the Nuclear Power Industry", February 1991.
Prior to the issuance of~NUREG-i 1397, Nuclear Management and Resources Council (NUMARC) issued
'I NUMARC 90 -12,
" Design Basis Program Guidelines", October 1990. The l
NRC provided various ' ' comments to NUMARC with regard to this
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document but-generally believed it to provide a useful approach and worthwhile insights to those utilities undertaking design-bases programs of varying scope and also a positive step in an area that will continue to be of great importance.
The proposed Generic Letter states that no new requirements or modificationsfof existing requirements are imposed by the Generic
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Letter.
Although true, one statement in the proposed Generic
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Letter implicitly contradicts this.
One of the uses for the j
information requested in the Generic Letter is to assist the staff in prioritizing the staff's inspection program.
This could be read by licensees to mean that no response or a less than comprehensive response could result in increased inspection activities with the
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corresponding expenditures of facility resources. Since this would.
be in. conflict with the voluntary nature of the request, we
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recommend that the phrase "To assist the staff in prioritizing its inspection program, be deleted from the proposed Generic Letter.
If the phrase is to. remain, we request that the staff explain within the Generic Letter, the methodology by which the inspection program would be prioritized in light of a specific response by a licensee.
If the NRC's intentions are to' gather 3
information on who has developed the best programs and use the
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i Chief,' Rules and Directives Review Branch i
B14457/ Attachment 1/ Page 2 l
April.23, 1993 results to prepare an inspection module or other regulatory document, we believe that the backfitting implications of such an undertaking would need to be addressed.
If the NRC decides to issue a Generic Letter, and the responses
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' received are to be used for prioritizing its inspection program, then CYAPCO and NNECO believe it would not be appropriate to use the voluntary information to develop any form of inspection manual chapter.
To do so would be contrary to the NRC's existing policy -
that "self-initiated DDR Programs should not be directly inspected" under normal circumstances [ Enclosure #3 to SECY-90-365. (January i
29, 1991)].
One could anticipate that only the best elements of
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various programs would be gleaned.by the NRC from-the voluntary utility submittals, and the results may not represent-a necessary or appropriate threshold for many utilities.
It is also possible.
that NRC inspectors could interpret utility submittals to be
" commitments" that would be inappropriately subjected to future inspection.
Technical Aspects CYAPCO and NNECO suggest that the terminology
" design basis programs" be used consistently throughout any NRC correspondence i
dealing with this effort.
There are several words that are used in j
the industry without clear definition.
For example, the use-of
" Design Basis Reconstitution" may have a different meaning to some utilities who might have classified their programs as " Design Basis j
Reconstruction" or " Design Basis Recompilation".
The terminology
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" Design Basis Reconstitution or Design Basis Reconstruction" could i
be interpreted as a program that would create-information that was not prepared ~
required as part of the original design, in or addition to identifying and organizing the existing information.
- However, some may interpret the goal as only compiling and' organizing existing data.
If the Generic Letter is issued, a discussion should be presented-l on the expectation that the various design basis programs could be limited to appropriate safety related systems. Clearly, non-safety related systems, such as domestic water or plant industrial air systems, have no impact on public health and safety and need not fall into the auspice of any licensee's design basis program.
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