ML20140E730

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Comments on Future Licensability of Plants,Per .If Util Maintains Equipment & Structures Per QA Program, Delay Will Not Adversely Effect Plant Licensability.Nrc Will Continue to Conduct Periodic Audits of QA Programs
ML20140E730
Person / Time
Site: Satsop, Washington Public Power Supply System
Issue date: 05/03/1985
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Mazur D
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
Shared Package
ML20140E734 List:
References
NUDOCS 8505080106
Download: ML20140E730 (3)


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UNITED STATES

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MAY 0 31985

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Docket Nos.:

50-460 and 50-508 RECEWED i

M AY 0 7 "~iS5 Pr. D. W. Mazur, Managina Director Wadington Public Power Supply System G.C.SORENSEN Post Office Box 968 3000 George Washington Way Richland, Washington 99352

Dear Mr. Mazur:

Sub.iect: NRC Comments on Future Licensability of WNP-1 and WNP-3 In response to your letter dated February 15, 1985, our coments are as follows:

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If the Supply Systen maintains equipment and structures in accordance with the QA Program and the Preservation Progran, we do not believe q

that the delay period will have an adverse 'effect upon plant ligensability.

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We are not aware of any future regulatory changes that will likely seriously challenge the licensability of those plants prior to their completion in the early 1990's.

Currently, the licensability of the subject units has been maintained in 6

areerdance with NRC regulations through the implementatior, af an NRC Region V reviewed and approved QA Program and the present short ter weservation a

Program for maintenance of equipment and structures.

It is aur understanding that the Supply System is now in the process of reviewing these programs for long term maintenance needs and plans periodic evaluations of the preservation progran to assure that it is or is modified to remain effective in assuring licensability of the units. We understand that records will continue to be maintained, adverse offsite environmental impacts avoided, and reportinq requirements such as 10 CFR 50.55(e) will be continued during the period of construction suspension. The NRC will continue its oresent practice of conductino periodic audits of the Supply Systems' i.r.plementation of the 0A and preservation programs durinq the suspension.

If such programs are effectively implemented, we believe the long term potential licensability of the units in terms of preserving structures, equipment and records can be maintained.

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During the period of construction suspension, the Connission will at times find that operating experiences and other developments nay require additional requirements be placed on licensees in order that the design, construction and operation will assure the public health and safety.

In view of the nunber of plants that have been postponed during construction, the staff will consider the legal and technical ramifications should a utility desire to reactivate a project af ter construction and licensing has stopped.

Procodures for such projects should be developed by the end of 1985.

While there are a number of generic issues under review by the NRC, we should emphasize that all proposed generic requirements are required to be reviewed by the Committee to Review Generic Requirerents prior to issuance to ensure they are warranted. Although regulations tend to change with time, we should also emphasize that the NRC has recently strengthened internal procedures that should ensure any plant specific backfits are limited to only those that can be clearly justified.

I trust that this response will prove helpful in ynur assessing the future licensability of Units 1 and 3.

Sincerely, i

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(yy William ! Dircks Executive Director for Operations l

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Mr. V. Stello Acting Executive Director for Operations

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