ML20129H668

Responds to Generic Ltr 85-07, Implementation of Integrated Schedules for Plant Mods. Amend to License Unnecessary for Implementation of Schedule.Plant Alterations in Response to Accident Nearly Complete

ML20129H668
Person / Time
Site:	Maine Yankee
Issue date:	07/12/1985
From:	Whittier G Maine Yankee
To:	Thompson H Office of Nuclear Reactor Regulation
References
GDW-85-198, GL-85-07, GL-85-7, MN-85-133, NUDOCS 8507190297
Download: ML20129H668 (4)

Text

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9 MnME HARHEE ATOMMPOWER00MPARUe avausra?lain"e%

% (207) 623-3521 9

July 12, 1985 MN-85-133 GDW-85-198 Director of Nuclear Reactor Regulation United SP.ates Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. Hugh L. Thompson, Jr.

Director, Division of Licensing

References:

(a) License No. DPR-36 (Docket No. 50-309)

(b) USNRC Letter to MYAPCo dated May 2, 1985 -

Implementation of Integrated Schedules for Plant Motidifications (Generic Letter 85-07)

Subject:

Response to Questions Posed in Generic Letter 85 Integrated Schedules Gentlemen:

Maine Yankee Atomic Power Company appreciates the opportunity to comment on the NRC's statement of policy and planning concerning the implementation of integrated schedules for power reactor licensees. We also appreciate the positive approach outlined in the Generic Letter and the attitude of cooperation expressed therein. -

Maine Yankee concurs with the concept of integrated strategic planning for the implementation of plant alterations, not only for regulatory requirements, but also for plant betterment projects. Such planning is an essential part of good management and the prudent husbandry of scarce resources in any field.

It is particularly important in a capital intensive enterprise such as nuclear power generation. We do not believe, however, that implementation of such a schedule requires a license amendment, nor do we think that a license amendment approach is necessarily desirable. Maine Yankee has, in general, been successful at negotiating implementation schedules for backfits through our NRR Project Manager.

Several factors suggest that the rigidity of the license amendment is unnecessary. Plant alterations coming out of the experience of the Three Mile Island accident are nearly complete. We and others in the industry anticipate a significant reduction in the number of backfits required in the future.

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MAINE YANKEE ATOMIC POWER COMPANY United States Nuclear Regulatory Commission Page Two Attention: Mr. Hugh L. Thompson, Jr. , Director MN-85-133 l Additionally, while the NFC's interest should only concern plant alterations which affect safety, by making the scheduling process a license condition, the Staff is inevitably drawn into management decisions which are outside their area of responsibility. We believe this is an untenable '

position for both the regulator and the licensee.

As we have done in the past, Maine Yankee will work cooperatively with our Project Manager and the NRC staff to develop appropriate schedules for implementation of backfits which are required to protect the public health and safety.

l Very truly yours, MAINE YANKEE ATOMIC POWER CO WANY

.&a+SE G. D. Whittier, Manager Nuclear Engineering & Licensing l GDW/bjp

Enclosure:

2 Pages

! cc: Mr. Edward J. Butcher, Jr.

l Dr. Thomas E. Murley Mr. Cornelius F. Holden t

6119L-FWS i

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b m ENCLOSURE 2 RESPONSE FORMAT - GENERIC LETTER 85-PLANT NAME: - Phine Yankee ,

UTILITY: Maine Yankee Atomic Power Comoany I. INTENTIONS A. Intend to work with the staff to develop an ILS B. Have reservations that must,be resolved before. developing ILS C. Do not presently intend to negotiate an ILS with the staff X D. Plan to implement an informal ILS only II. STATUS-A. If you answered I.A above:

1. Have you settled on a method for prioritizing the work at your plant (s)?

Circle One: Yes No If yes, select best description:

Engineering judgement Analytic Hiearchy process Risk based analysis Cost-benefit analysis Other (please describe)

If no, provide estimated date for selecting a methodology:

Date or If not presently available, provide estimated date for scheduling the selection of a methodology-

2. L' hat,jk' your estimated date for making a submittal to the NRC-or If not* presently-available, planned date for scheduling a submittal to the NRC i:

. a B. If you answered I.B above:

1. Please explain your reservations on' separate sheet (s) or provide your schedule for supplying an explanation See separate sheet (s) or Separate submittal scheduled for (Date) u

2. If available to meet with the staff to discuss your concerns, propose a time frame for such a meeting and r

provide a contact that can make arrangements Contact / Time Frame Phone Number 4

C. If you answered I.C

1. Would you be willing to meet with the staff to discuss the development of an ILS for your facility (s)?

Circle One: Yes

()

If yes, propose a time frame for such a meeting and provide a contact that can rake arrangements.

Contact Tine Frame Phone Number i If no, any_ constructive comments you have would be appreciated.

III. ADDITIONAL ITEMS Please make any suagestions you may have as to how a utility sponsored

availability / reliability pro.iert night be credited for plant safety enhancement. Provide additional constructive comments as appropriate.

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