ML20072C531
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VERMONT YANKEE NUCLEAR POWER CORPORATION BVY 89-47
. q' Ferry Road, Brattleboro. VT 05301-7002
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ENGINEERING OFFICE
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l 580 MAIN STREET BOLToN MA 01740 t508i 779-6711 May 18, 1989 Mr. Edward L. Jordan, Director Office for Analysis and Evaluation of Operational Data U.S. Nuclear Regulatory Commission Washington, D.C.
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References:
a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, USNRC to All Licensees, dated 4/7/89
Dear Sir:
Subject:
Response to AEOD Questionnaire Regarding Backfitting In response to the AEOD request for comments on licensees' views of the backfit process that was transmitted as Reference b), Vermont Yankee Nuclear Power Corporation submits the enclosed.
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) of this letter addresses the bac'< fit rule in a general manner i
rather than a response to the specific questions given in Reference b).
l Additionally, Vermont Yankee has included, as Enclosure 2, the specific cost l
estimates requested for the applicable actions listed in Reference b).
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We appreciate the opportunity to provide input on this important subject.
Should you have any questions regarding our comments, please do not hesitate to
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Contact us.
Very truly yours, I
VERMONT YANKEE NUCLEAR POWER CORPORATION 1
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Warren P. Murp..y l
Vice Pre ident a; Manager of Ope ations
/dm 9408170275 940629 PDR COMMS NRCC CORRESPONDENCE PDR
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ENCLOSURE 1 l
RESPONSE TO AEOD SURVEY ON l
THE NRC BACKFITTING PROCESS 1
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General Comments l
Generally, Vermont Yankee believes the backfitting rule has bad a positive j
impact on utilities and the NRC's management of the backfit progest-although i
we do believe there exists some areas where the rule could be acplicd by the
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t staff in a more consistent manner. Specifically, the application of the backfit rule: what constitutes a backfit? how are backfits identified? what is the appropriate vehicle for appealing what the licensee may feel is a misapplication of the rule? An increased sensitivity on the part of the staff with regard to the proper use of 10CFR50.54(f) and 10CFR50.109 would be a significant contribu-tion to achieving this desired stability.
In addition, Vermont Yankee believes the increased use of generic communications such as Bulletins and Generic Letters as a method to initiate new licensee programs or expand the interpreta-tions of the regulations should be examined. These generic backfitting pro-cesses have created a substantial drain on licensee resources.
In order to i
meliurate this process, a detailed review of the regulatory basis, backfitting analysis, and estimates of the burden of addressing the generic communication.
including the burden of any continuing licensee action, should be accomplished l
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The backfit rule is the single most important tool the NRC has available to ensure that new requirements truly improve plant safety and not unnecessarily consume licensee and NRC resources. Close adherence to the intent of the back-fit rule in all potential backfit situations will further the public interest.
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I i-ENCLOSURE ?
j RESPONSE TO AEOD REQUEST FOR SPECIFIC IMPLEMENTATION COSTS i
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NRC Bulletin 88-01:
$400.00 Engineering Review j
$1000.00 Search Defects in Westinhouse Breakers
$1400.00 Total
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i NRC Bulletin 88-02:
N/A 1
l Rapidly Propagating Cracks in S/G Tubes
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i NRC Bulletin 88-05:
$2500.00 Vendor Engineering
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$5400.00 Engineering l
Non-Conforming Material Supplied by
$1000.00 Travel j
Piping Supplies, Inc., & Jersey
$8900.00 Total Manufacturing i
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Generic Letter 88-01:
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$8000.00 Vendor Engineering j
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$8000.00 Total BWR Austinetics s
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i Generic Letter 88-03:
N/A Steam Binding of Auxiliary Feedpumps i:
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