ML20072C445
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I Northem States Power Company
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414 Nicollet Mall Minneapohs, Minnesota 55401 1927 M
22, 1989 Telephone (612) 3305500 i
l Mr Edward L Jordan, Director l
Office for Analysis and Evaluation of Operational Data U S Nuclear Regulatory Commission Washington, DC 20555 MONTICELID NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License No. DPR-42 50-306 DPR-60 Comments on Conduct of NRC Backfit Process The purpose of this letter it to provide our response to your April 7, 1989 request for information related to the NRC backfit process for the Monticello and Prairie Island Nuclear Generating Plants.
Re-sponses to Attachments (1) and (2) of your letter are provided below.
Response to Attachment (1) - Questionnaire
- 1. Are NRC Procedures (i.e. Manual Chapter 0514) sufficiently clear and effective on how backfits are identified and transmitted to licenseees, and how claims of backfit and appeals are handled? If not, would you please comment on the need for specific improvement?
Response
We did not receive a copy of the referenced manual and are not familiar with it.
We are generally familiar with the NRC process, however, and have our own internal process for addressing backfit issues.
- 2. Is NRC staff practice consistent with the 0514 process in identifying and implementing backfits? If not, would you please comment on any specific observed inconsistencies?
Response
We are unable to comment on the matter of PRC conformance to the 0514 process.
9408170246 940629 PDR COMMS NRCC CDRRESPONDENCE PDR v
1 E L Jordan Northem States Power Company May 22, 1989 Page 2
- 3. In the past year have you experienced, in your judgment, the imposition of one or more backfits, which would not fit one of the exceptions listed in 10 CFR 50.109(a)(4) or did not have a regulatory analysis, for which you did not fire a claim or appeal? If so, please indicate why you did not file a claim or appeal.
Response
l No.
- 4. Please describe any impediments or weaknesses in the backfit process, l
or j
in the communications and understanding of that process, and any i
l suggestions for improvements.
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Response
i We have no suggestions to offer.
1 Cost estimates for the selected generic actions completed during 1987-1988 are provided in the attached table.
Please contact me if you have any questions related to our response.
i David Musolf Manager Nuclear Support Services Attachment c: Sr Resident Inspector Monticello Sr Resident Inspector Prairie Island NRR Project Manager Monticello NRR Project Manager Prairie Island Regional Administor, Region III, NRC G Charnoff
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E L Jordan May 22, 1989 Attachme'it Bgekfits Iarosed in 1988 Estimated Cost ($)
Issue Monticello Prairie Island Comments
- 1. NHC Bulletin 88-01
$400
$400
$0
$183,300 Not applicable to Monticello
$65,200
$97,800 4
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- 4. Generic Letter 88-01 $66,700
$0 Not Applicable to I
Prairie Island A request for additional information related to Generic Letter 88-01 has been received which will require an estimated cost of $8,300 to complete.
- 5. Generic Letter 88-03 $0
$51,900 Estimated $50,000 cost for replacement of two check valves and
$1,900 for engineering support.
Notes:
Unless otherwise noted, all estimated costs are for engineering evaluation, inspection, and testing. Only iten (5) involved significant new equipment and installation costs.
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