ML20044D327
| ML20044D327 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 05/07/1993 |
| From: | Bowling M VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC |
| References | |
| FRN-58FR1885 58FR1885, 93-269, NUDOCS 9305190004 | |
| Download: ML20044D327 (1) | |
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May 7,1993 l
i Chief, Rules Review and Directives Branch Serial No.93-269
(
U. S. Nuclear Regulatory Commission NL&P/RBP Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY COMMENTS ON PROPOSED GENERIC LETTER I
AVAILABILITY AND ADEQUACY OF DESIGN BASES INFORMATION Virginia Power has reviewed the Nuclear Regulatory Commission's (NRC's) Federal Register notice dated March 24,1993 which proposed to issue a generic letter on the availability and adequacy of design bases information. The draft generic letter specifically requests power reactor licensees to describe the programs that are implemented or planned to ensure design bases information for their facilities is correct, accessible, and maintained.
i We endorse the NUMARC comments sent separately to the NRC which oppose i
issuance of the proposed generic communication. Although we are presently and voluntarily conducting a design basis information program, we believe that the generic
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letter may represent an unjustified regulatory burden with implied backfit implications l
which does not have any direct connection to public health and safety. We suggest that the NRC apply a 10 CFR 50.109 backfit analysis to this issue, specifically to the i
effort necessary in describing the extent of any information not presently obtained or providirg a rationale for not implementing such a program. Based on our efforts to date, this is substantial and with very limited safety significance.
l Very truly yours, l
i M. L. Bowling, Manager Nuclear Licensing and Programs 9305190004 930507 PDR ORG NRRB PDR