ML20247D780
| ML20247D780 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/19/1989 |
| From: | John Marshall TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-001, IEB-88-1, TXX-89284, NUDOCS 8905260001 | |
| Download: ML20247D780 (2) | |
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MFE Log # TXX-89284 File # 891 l
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TUELECTRIC May 19, 1989 William J. Cahill Jr.
Executive Vice President U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS, 50-445 AND SJ-446 RESPONSE TO AEOD QUESTIONNAIRE ON CONDUCT OF BACKFIT PROCESS Gentlemen:
We appreciate your request to obtain TV Electric's views on how the backfitting rule is working in practice.
In short, our views (for the most part) are captured in the Nuclear Utility Backfitting and Reform Group (NUBARG) response of which we are a part.
However, TU Electric is providing the following general observation in the implementation of the backfit rule:
The utility's right to file a backfit claim with the staff provides a method for the utility to formally disagree with the staff.
However, the NRC should provide e sound method of screening all formal correspondence with licensees such that this process does not become a primary means to identify a backfit. Although this is an accepted method for identifying a backfit under the regulation, putting the burden on licensees to identify a backfit at this stage of formal interface with the staff provides a breeding ground for poor relations between the staff and the utility of which one result could be an impact to SALP ratings.
1 In addition, the estimated cost for implementation of NRC Bulletin 88-01 is provided in the attachment to this letter.
Please contact me if you have any questions concerning this response.
Sincerely, William J. Cahill, Jr.
8905260001 890519 PDR ADOCK 05000445 g#.*
A PDC f S. Marshall Generic Licensing Manager l
JOS/vid Attachment c - Mr. R. D. Martin, Region IV f
Resident Inspectors. CPSES (3) i j 400 North Olive Street LB 81 Dallas, Texas 75201
Att a chr.n t. t o.. TX'X -89284 l
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!4ay 19,1989 Page 1-' of ;1.
COST FOR BULLITIN 88-01 IMPLEMENTATION r
1)' Engineering Time 800
- 2) Replacement Poleshafts
$58,464
- 3) Receipt Inspection 320 i
- 4) Work Order Planning
$ 2,080
- 5) Craft Installation
$ 3,840
- 6) OC Inspection 480 Total estimated cost
$65,984 l-l
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