ML20072C455
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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 2247 402/536 4000 June 9, 1989 LIC-89-506 Mr. Edward L. Jordan, Director Office for Analysis and Evaluation of Operational Data U. S. Nuclear Regulatory Commission Mail Station PI-137 Washington, DC 20555
Reference:
1.
Docket No. 50-285 2.
Letter from Edward L. Jordan (NRC) to All Licensees of Operating Reactors and Holders of Construction Permits, l
dated April 7, 1989
Dear Mr. Jordan:
SUBJECT:
NRC Backfit Questionnaire Omaha Public Power District (OPPD Attached please find our response)to your questionnaire. received the letter in Refe Cost estimates for two of the generic actions listed in Attachment 2 of your letter have been determined for the Fort Calhoun Station. As requested, this information is provided and represents estimated costs by category based upon engineering judgement.
I hope this information will assist you in your evaluation of the backfit process.
If you have further questions on this, please contact me or members of my staff.
Sincerely, K.
. Morris l
Division Manager Nuclear Operations KJM/jak Attachments c:
LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector i
l 9408170250 940629
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PDR COMMS NRCC CORRESPONDENCE PDR 4sse4 tmaiovmengun tou opponunau
Questionnaire l
1.
Are NRC procedures (i.e., Manual Chapter 0514) sufficiently clear and effective on how backfits are identified and transmitted to licensees, and how claims of backfit and appeals are handled? If not, would you please comment on the need for specific improvement?
OPPD Resognig The NRC manual chapter provides sufficient procedural guidance on the provisions for backfitting.
Responsibilities, requirements, and guidance i
for NRC implementation of backfitting appear to be clear and well-defined.
l 2.
Is NRC staff practice consistent with the 0514 process in identifying and implementing backfits? If not, would you please coment on any specific observed inconsistencies?
OPPD Response l
This issue has had little or no impact on Fort Calhoun Station, therefore, OPPD cannot provide practical comment.
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 file a claim or appeal? If so, please indicate why you did not file a claim or appeal.
l OPPD Resoonse The imposition of such beckfits has not affected Fort Calhoun Station in the past year.
4.
Please describe any impediments or weaknesses in the backfit process, or in the comunications and understanding of that process, and any suggestions for improvements.
OPPD Response The backfit process is difficult to assess for impediments or weaknesses since this issue has had little or no impact on Fcrt Calhoun Station.
l However, the new manual chapter provides sufficient clarity in understanding this process.
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i Backfit Cost Estimate Information i
NOTE: Only two of the issues listed in Attachment 2 of the questionnaire affected Fort Calhoun Station; NRC Sulletin 88-05 and Generic Letter 88-03.
1 1.
NRC Bulletin 88-05, "Non-conforming materials supplied by Piping Supplies, Inc., West Jersey Manufacturing, and Chews Landing Metal Manufacturers, Inc."
Enoineerina Sunoort Cost Estimate Metallurgist contractor support
$ 4,000 Sargent & Lundy support 73,600 OPPD Engineering support 25.000 Total
$102,600 (Other category costs not applicable) 2.
Generic Letter 88-03, " Resolution of Generic Safety Issue 93, Steam Binding of Auxiliary Feedwater Pumps" Enoineerino Suonort Cost Estimate OPPD design and drafting
$ 3,000 Eauioment 1
Two bimetal surface thermometers 80 Installation Labor and overhead 40 Total ~
$ 3,120 (Facility downtime not applicable)