ML20244D303

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Ltr to All Licensees of OLs & CPs Forwarding Questionnaire to Obtain & Evaluate Industry Views on Conduct of Backfit Process.Response Requested by 890519
ML20244D303
Person / Time
Issue date: 04/07/1989
From: Jordan E
NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To:
AFFILIATION NOT ASSIGNED
References
NUDOCS 8904210275
Download: ML20244D303 (3)


Text

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, April 7','1989

[' '

ip T0: -ALL LICENSEES OF OPERATING REACTORS AND HOLDERS OF CONSTRUCTION

. PERMITS

. De'ar Sir: .

The backfitting of nuclear power reactors is an integral part of NRC's regulatory process. To assure that it is performed in a. responsible manner, the NRC has developed an implementing procedure which includes an internal oversight function. The procedure is defined and discussed in NRC Manual j Chapter 0514. A copy was forwarded to you by my letter dated December 12 -

-1988.

One of my responsibilities is .to obtain and evaluate industry views on the conduct of the backfit process. In order to accomplish this function, a short questionnairehasbeenprepared(attached). I would appreciate your response to this questionnaire, as well as any other comments you wish to provide by-May 19, 1989. I 1

In addition, a listing of selected generic actions completed during 1987 1988 is included.~ If you have determined or have detailed estimates of your plant

' specific implementation costs for any of the items listed, please provide them in your response. This will assist us in determining the accuracy of staff  ;

estimates used in backfitting determinations. Your response is voluntary, yet '

your assistance and feedback would be of great benefit in our review and in helping the NRC to meet its commitments in a responsible manner.

This request is covered by Office of Management and Budget Clearance Number 3150 0011, 'which ex) ires December 31, 1989. The estimated average burden

. hours is 20 person-1ours )er owner response, including searching data sources, gathering _and' analyzing tle data, and preparing a response. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Records.and Reports Management Branch, Division of Information Support Services, Office of Information Resources Management, U.S. Nuclear Regulatory Comission, Washington, D.C. 20555;andtothePaperworkReductionProject(3150-0011),

Office of Management and Budget, Washington, D.C. 20503.

Thank you for your time and effort.s in this matter. Your responses can be sent to me directly. Should you have any questions on this request or the associated enclosures, please call Jack Heltemes or Cheryl Sakenas on 301-492-7361. '

Sincerely, OrigioM Mpac tepa n a.re m m .ta.

8904210275 890407 Edward L. Jordan, Director PDR ORG NEXD Office for- Analysis and Evaluation Attachments:

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0FFICIAL RECORD COPY

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L Attachment 1 Questionnaire

1. Are NRC procedures (i.e., Manual Chapter 0514) sufficiently clear and effective on how bat.kfits are identified and transmitted to licensees, and how claims of backfit and appeals are handled? If not, would you please coment on the need for specific improvement?
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?
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.
4. Please describe any impedi:nents or weaknesses in the backfit process, or ]

in the communications and understanding of that process, and any suggestions for improvements.

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Attachment 2

. Backfits Imposed in 1988 Issue Actual Cost

1. NRC Bulletin 88-01
2. NRC Bulletin 88-02
3. NRC Bulletin 88-05
4. Generic Letter 88-01
5. Generic Letter 88-03 If available, please provide this information by category (i.e. , engineering support, equipment, installation, and facility downtime).

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