ML20058J235
| ML20058J235 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 08/05/1982 |
| From: | Denise Edwards YANKEE ATOMIC ELECTRIC CO. |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| FYR-82-83, GLA-82-84, NUDOCS 8208090206 | |
| Download: ML20058J235 (2) | |
Text
o Telephone (617) 872-8100 TWX 710 380 7619 YANKEE ATOMIC El.ECTRIC COMPANY FYR 82-83 GLA 82-34 Yau*xus.
1671 Worcester Road, Framingham, Massachusetts 01701 1
August 5, 1982 United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention:
Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing
References:
(a) License No. DPR-3 (Docket No. 50-29)
(b)
D. M. Crutchfield Letter to SEP Phase Il Licensees, dated July 14, 1982
Subject:
SEP III Opinions
Dear Sir:
Yankee Atomic was not an addressee of your Reference (b) letter to some other SEP Phase II licensees. Our Project Manager advises that our perspec-tives, as a Phase II participant, could be meaningful to discussions concerning the value of SEP. Subsequently, we obtained a copy of Reference (t), aid we would like to offer a response below in the hope that you may find our commenia useful, even though we were unable to provide them by your requested date.
As you are aware, Yankee has conducted its own integrated safety assessment, concluding the SEP for our facility in Rowe, Massachusetts. We will legin reviewing our integrated assessment with the staff in September.
Thus, any data we might provide at this time would be tentative. Our opinion, briefly stated, is that the NEC may not have enough information at this time, concerning the value of SEP Phase II, to address the important questions of concept and implementation for SEP Fhase III.
A conclusion could be drawn regarding the value of SEP, based upon the two assessments that have been completed, that SEP appears to be an inef ficient process for gathering information on a relatively few significant issues. Our review of the draft NUPEG for Palisades, for exampic, shows that the only apparent major area of concern was electrical equipment anchorages, although 31 other topics received some attention.
Palisades ' owners, however, estimate that some 20 man years and $2.3 million in contractor costs over the past five years were necessary to complete its SEP.
These statistics cannot easily be construed, however, to either confirm or refute the actual significance of SEP rhase II.
They rust first te expressed in terms of some benefit to public health and safety. Only then can the question te answered, whether the costs for Palisades were justified.
Similarly, until all results are in for the remaining plants participating in Phase II, the overal] merits of the program cannot easily te assessed. We 8208090206 820805 8
PDR ADOCK 05000029 P
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United Stctes Nuclear Regulatory Commission August 5, ICE 2 Attention:
Mr. Dennis M. Crutchfield Page 2 believe, therefore, that the best course of action is to suspend any decision on further SEP activities until we know the real score on Phase II.
The Yankee Plant is significantly different from Palisades.
Individual topic evaluations for our plant were more difficult because of a greater historical dissimilarity between the regulatory design-basis for the plant and the Standard Review Plan's criteria.
It would seem that plants more contemporary than Falisades might not require a complicated and costly review to the Standard Review Plan's criteria, like SEP Fhase II plants received. If a continuing SEP review is contemplated, the lessons learned from Phase II would firmly suggest that the number of topics and scope of evaluation should both be substantially restricted.
Tangible benefits have accrued from SEP and though they may be somewhat indirect, they are benefits nevertheless. First, the NRC SEP branch was a protective middleman between SEP licensees and the other technical branches helping to shield the owners from simultaneous and competing SEP regulatory demands. Second, the integration of topics via superimposing resolutions has afforded the opportunity for NRC and licensees to be more creative when integrating related required actions, thereby facilitating modificaticns to systems or other upgrading in a more optimal manner.
Although specific to SEP, these benefits could be generalized into the licensing process with little difficulty and with great benefit for improved public health and safety. The first, increased discipline over ad-hcc staff demands, could be realized by a strengthening of the project management function within the NRC.
This could be accomplished either by a careful assignment of personnel and by enhanced authority at the project manager level. The living schedule concept, which is gaining acceptance within the NRC and the industry, can be effective in achieving integration of numerous activities af fecting a single facility. This living schedule concept could produce, independent from SEP, an optimal plant-specific program aimed at safety improvements.
In summary, we urge the NRC to avoid prematurely launching another phase of SEP now, before the true value of Phase II has been determined, and before other regulatory programs, due in the near future, are completed (i.e., severe accident rulemaking and the integrated reliability program). A delay in starting any further evaluations would not be unproductive.
Instead, the NBC could be devoting its efforts to establishing a cohesive and rational backfit policy, together with a revised version of the current backfit rule.
Very truly yours, hh5m f-D. W. Edwards, Director Operational Projects & Licensing DWE/REH/ dad