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. j WPSC (414) 433-1598 TELECOPIEA (4141433-5544 EASY INK 62891993 WISCONSIN PUBUC SERVICE CORPORATION j
600 North Adams e P.O Box 19002
- Green Bay, WI 54307-9002 I
May 19, 1989 Mr. Edward L. Jordan Office for Analysis and Evaluation of Operational Data U. S. Nuclear Regulatory Commission Mailstop MBB3701 Washington, D.C.
20555
Dear Mr. Jordan:
Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Backfit Questionnaire This submittal is in response to your letter of April 7,1989, requesting feedback from licensees on the backfit process. This request included a questionnaire and a list of generic actions implemented during 19E7-1988 time frame. While Wisconsin Public Service Corporation has no basis to complete the questionnaire form, we can provide you with some cost estimates for the specified generic actions. This information is provided in the attachment to this letter.
Sincerely, dF C. R. Steinhardt Manager - Nuclear Power SLB/jms
- Attach, cc - Mr. Robert Nelson, US NRC US NRC, Region III US NRC, Document Control Desk 9408170280 940629 PDR CDPfPts NRCC CDRRESPONDENCE PDR h
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Mr. Edward L. Jordan
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May 19, 1989 N355.2 NRC Backfits in 1988 Issue Estimated Cost 1.
NRC Bulletin 88-01 NA for WPSC 2.
NRC Bulletin 88-02 Consultant Support
$67,750 WPSC Engineering 12,640 Miscellaneous Cost of Implementation 9,654 TOTAL
$90,044 3.
NRC Bulletin 88-05 Equipment
$12,150 WPSC Engineering / Maintenance a' QC 22,800 Miscellaneous Cost of Implementation 5,501 TOTAL
$40,451 4.
Generic Letter 88-01 NA for WPSC 5.
Generic Letter 88-03 WPSC Engineering S 3,200 Miscellaneous Cost of Implementation 320 TOTAL
$ 3,520 6.
Response to Backfit Questionnaire Approximately 25 person-hours 4
N W$LF CREEK NUCLEAR OPEPMTING CORPOMTION Bert D. Withers Pros ces.,awa arms e omo.,
May 19, 1989 iiH 89-0156 U. S. Nuclear Regulatory Commission ATTH: Document Control Desk Mail Station F1-137 Washington, D. C. 20555 Reference Letter dated April 7, 1989 from E. L. Jordan, NRC to All Licensees of Operating Reactors
Subject:
Docket No. 50-482: Backfitting Questionnaire
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Gentlemen:
Attached is Wolf Creek Nuclear Operating Corporation's (VCNOC) response to the questionnaire provided by the NRC in the Reference.
In addition, a
table is included which gives approximate implementation costs incurred by WCNOC to complete the items identified in the Reference as 1988 backfit issues-VCNOC believes the effective implementation of the backfit procedures is an essential element of the management of the regulator 3-process.
Therefore, WCNOC is pleased to see that the NEC management is interested in the Licensees' views on the effectiveness of the process.
Please contact me or Mr. O. L. Maynard of my staff if you have any questions relative to the attached response.
Very truly yours, A
-,vW Bart D. Withers President and Chief Executive Officer BDW/jad Attachment cc:
B. L. Bartlett (NRC), w/a E. J. Holler (NRC), w/a 0
R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a jF228!'ca88Qpq'yd. P.O. ham 411/ auringon, Ks essas / Phone:(31
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N Attcchment to WM 89-0156 Page 1 of 4 Ouestion 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 consnent on the need for specific improvement?
Resnonse to Ouestion 1 WCNOC believes the current NRC procedure is sufficiently clear and effective on how backfits are processed once they have been identified.
However WCNOC does not believe the procedure is sufficiently clear and effective on how backfits are identified.
The procedure does not require documentation that staff positions have been evaluated to determine whether the position qualifies as a potential backfit. Therefore, there does not appear to be a way for NRC management to assure themselves that section 042 of Manual Chapter 0514 is being implemented.
Th documentation could be as simple as a checklist that the staff completes prior to issuance of a letter or initiation of a phone call in which the staff is going to be requesting or recommending action of a Licensee.
WCNOC believes the documentation should be maintained and periodically reviewed by NEC management to provide assurance that the procedure is being properly implemented.
One essential element of compliance with Manual Chapter 0514 which could be included in the checklist is to identify and document the applicable regulatory position upon which the action is based.
If there is no applicable regulatory position and the staff's request is truly a reca==endation or request, then the NRC should so identify the request /reccomendation.
The Staff should place aGitional emphasis on the internal identification of backfit issues so that these issues can be thoroughly evaluated initially by the Staff, thereby minir.izing the number of licensee requested backfit evaluations.
Question 2 Is NRC staff practice consistent with the 0514 process in identifying and implementing backfits?
If not, observed inconsistencies?
would you please comment on any specific Resoonse to Question 2 WCN00 does not believe the NRC staff practice is always consistent with the intent of 0514 relative to identifying plant specific backfits.
Inspectors and ether NRC staff seldom provide a ' position
- Or
- require' a specific new action.
- Instead, issues are left open and additional /
information requested until the Licensee comunits to additional action.
Failure to close issues is generally eeen by the NRC staff as 'non-responsiveness' on the part of the Licensee and can result,in increased inspection and enforcement.
Some specific examples of this at Wolf Creek are provided below:
1.
Vital Area Access
- A question relative to vital area access has been open since 1985.
WCMOC recently elected to propose changes in-.
an attempt to get the item closed. The 1988 SALP report originally identified the lack of timely resolution of this item as a weakness on the part of the Licensee.
challenged by WCNOC and revised by the NRC staff.This statement was subsequently
i i
Attachment to WM 89-0156 Page 2 of 4 2.
WCNOC recently made changes in its Beergency Preparedness Plan (RPP) relative to Emergency Action Levels in order to close an open item which dated back to 1984.
WCNOC's prior position had been extensively documented and submitted to the NRC during the j
preparation of the RPP.
At that time the NRC Staff reviewed and accepted that position.
Subsequent discussions between WCNOC and j
the NRC Staff essentially resulted in a revised staff position, which made WCNOC's EPP changes necessary.
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Ouestion 3 In the past year have you experienced, in your judgement, 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.
Resoonse to Question 3 During the past year there were two NRC staff positions that WCNOC would consider as backfits. Bowever, WCNOC did not file a backfit claim on either NRC staff position.
One involved a Region IV position which basically required WCNOC to consider any system or component that did not meet all of the ASME code requirements as inoperable.
A more reasonable position has-since been agreed upon.
WCNOC did not file a backfit claim because of pending escalated enforcement action relative to an Operability question..
The second involved a Region IV position that required WCNOC to take' securitycompensatorymeasuresabovethoserequiredintheapprovedSecurity; Plan.
t backfit claim was not filed because WCNOC is attempting to improve' the perception of responsiveness with the Region IV security personnel.
Ouestion 4 Please describe any impediments or weaknesses in the backfit process, or in the casesunications and understanding of that process, and any suggestions for improvements.
Resoonse to Ouestion 4 The two most significant weaknesses in the backfit process are.the identification process and the cost benefit analysis.
As described in the response to Question 2 above, backfits can, in effect, be imposed without the NRC staff taking a documented position.
Backfit claims and disagreements over the validity of violations can result in a perception by the Staff that a Licensee is unresponsive.
UCNOC challenged one volation in the Security area during 1988 and identified that part of aaother violation would result in a Backfit claim if imposed.
In early 1989, a security inspection report contended that WCNOC was not as responsive to NRC.
initiatives as in the past.
perceptions play a large role in SALP ratings and in the level of confidenceWCNOCbelieve that NRC management has in a given Licensee.
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l Attachment to WM 89-0156 l
Psge 3 of 4 6
A good cost benefit analysis is extremely difficult to perform and requires considerable judgement and a number of assumptions.
These analyses are typically performed by individuals with incentive to show that a change is needed.
Accordingly an analysis may result in a higher benefit-to-cost ratio that might otherwise result in the absence of a bias towards change.
More objectivity and perhaps same industry input could improve the cost benefit analyses.
s Attachm:nt to WM 89-0156
,Page 4 of 4 TABLE OF PLANT SPECIFIC IMFrBNNTATIN COSTS 131u_p.,
Anoror4==te cost 1.
NRC Bulletin 88-01 (Defects in Westinghouse
$ 31,300 q
Circuit Breakers) 2.
NRC Bulletin 88-02 (Cracks in Steam Generator Tubes) 3.
NRC Bulletin 88-05 (Nonconforming PSI and WJM
$336,000 Materials) 4.
Generic Letter 88-01 (NRC position on IGSCC in BWR Austenitic Stainless Steel Piping) 5.
Generic Letter 88-03 (Resolution of Generic
$ 26,040 Safety Issue 93, ' Steam Binding of Auxiliary Feed-water Pumps")
- Minimal review costs incurred, issue was determined to be not applicable to Wolf Creek Generating Station
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