ML20247H077

Responds to NRC 890407 Questionnaire Re Backfit Rule.Backfit Procedure Appears to Be Sufficiently Clear on Identification of Backfits & Handling of Claims & Appeals

ML20247H077
Person / Time
Site:	Davis Besse
Issue date:	05/19/1989
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-GTECI-093, REF-GTECI-NI, TASK-093, TASK-93, TASK-OR 1665, GL-88-03, GL-88-3, IEB-88-005, IEB-88-5, NUDOCS 8905310153
Download: ML20247H077 (2)

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. I TOLEDO

%me EDISON i A Centenar Enegy Company -

DONALD C. SHELTON Vos Pneedent-Nuclear

. [419]P49 P300 Docket Number 50-346 License Number NPF-3

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Serial Number 1665 May 19, 1989 United Staten Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555  ;

Subj ect: Backfit Rule Questionnaire Response Gentlemen:

This letter is submitted.in response to the Nuclear Regulatory Commission's '

(NRC) questionnaire (Log Number 2884) dated April 7, 1989 on the backfit process. The NRC letter requests licensees to respond to four questions and to provide, if available, overall costs for action on several identified NRC Generic Lettera and Bulletins. The four questions pertain to the effectiveness and clarity of_the NRC backfit procedures, consistency of the j NRC staff in. identifying and implementing backfits, whether the utility has I considered that a'backfit had been imposed but did not appeal, and identification of weakness in the NRC backfit process.

Regarding questionnaire Item 1, based on a review of NRC Manual Chapter 0514, j

'the backfit procedure appears to be sufficiently clear on the identification i of backfits and handling of chims and appeals. Regarding questionnaire items j 2, 3 and 4, the NRC should note that Toledo Edison has not invoked the 10CFR50.109 backfit process and the associated NRC implementing procedures.

Therefore, the Toledo Edison's responses to the four questions are limited.

m< Toledo Edison participates in the Nuclear Utility Backfitting and Reform Group (NUBARG) who vill also be responding to the questionnaire with input from

.$ various plants. Since the comments from NUBARG will be based on the l 0 MS experiences of several plants which have been directly involved in the backfit L E "' process, Toledo Edison strongly encourages the NRC to consider the NUBARG's comments in the results of this survey.

CDs n A review of the selected generic actions (listed in Attachment 2 of the

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! April.7, 1989 NRC letter) for which the NRC requested information on available o implementation costs has determined that NRC Bulletin 88-05 (Nonconforming M Materials Supplied by Piping Supplies, Inc. at Folsom, New Jersey and West Jersey Manufacturing Company at Villiamstown, New Jersey) and Generic Letter i $

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THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 [N

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i Docket-Numbar-50-346

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• Licensa Numbar NPF-3 Serial Number-1665-

- Page 2 l 88 03:(Resolution of Generic Safe g Issue 93, " Steam Binding of Auxiliary l- 'Feedvater Pumps") were required tom be implemesited at the Davis-Besse Nuclear Power Station. Generic Letter 88-03 was implemented by changes ~to several operating procedures and no detail costs are readily available. The total costs to date on Bulletin 88-05 have been approximately $142,000 of which the majority is manpower costs..

Toledo Edison appreciates"the opportunity to provide input on thJs matter and again. urges'the Staff's consideration of the NUBARG response.

Should.further information be required, please contact Mr. R. V. Schrauder, Nuclear Licensing Manager, at (419)249-2366.

Very truly ours, 1

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GBK/dlm cc P. H. Byron, DBil NRC Senior Resident Inspector A. B. Davis, Regional Administrator, NRC Region III E. L. Jordon,_. Director, Office for Analysis _and Evaluation of Operational. Data T. V. Vambach, DB-1 NRC Senior Project Manager II h 3 -

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