ML20247H390

Forwards Responses to Backfit Questionnaire & Info Re Costs Associated W/Evaluations of Bulletins & Generic Ltrs

ML20247H390
Person / Time
Site:	Beaver Valley
Issue date:	05/19/1989
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-88-01, GL-88-02, GL-88-1, GL-88-2, IEB-88-001, IEB-88-1, NUDOCS 8905310226
Download: ML20247H390 (5)

Text

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1 aver Va ley Power Staton~

Shippingport, PA 150770004 L ?I.*nS.EE"no., cm,o <4i2> e4ms i

May 19, 1989 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 1 and No. 2 i BV-1 Docket No. 50-334, License No. DPR-66 DV-2 Docket No. 50-412, License No. NPF-73 NRC Backfit Questionnaire Gentlemen:

The purpose of this letter is to provide our response to the Bw.kfit Questionnaire and Costs associated with our evaluations in response to certain bulletins and generic letters. The

. Questionnaire. and Cost Request was transmitted by your letter dated April 7, 1989. Our response is attached.

Very truly yours, eL; W i

J. D. Sieber {

Vice President Nuclear Group j 1

Attachments cc: Mr. J. Beall, Sr. Resident Inspector Mr. W. T. Russell, NRC Region I Administrator Mr. P. Tam, Sr. Project Manager Edward L. Jordan, Director, Office for Analysis and Evaluation of Operational Data Director, Safety Evaluation & Control (VEPCO) ]

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foof 8905310226 890519

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PDR ADOCK 05000334 ,I P I PNV j

ATTACHMENT 1 l

Questionnaire

1. Are NRC procedures (i.e., Manual Chapter 0514) sufficiently clear and effective on how backfits are identified and transmitted to licensees, and how claims of' backfit and appeals are handled? If not, would you please comment on the need for specific improvement?

Response

Based on Duquesne Light Company's review of the procedures, we believe that the procedures are sufficiently clear. We cannot comment as to their effectiveness since we have not recently utilized them.

2. Is NRC staff practice consistent with the 0514 process in identifying and implementing backfits? If not, would you please comment on any specific observed inconsistencies?

Response

The only inconsistency that we would comment on is the cost justification for backfits. Frequently the cost-benefit grossly underestimates costs and provides anecdotal support for benefits. A more rigorous analysis would benefit the process greatly.

3. In the past year have you experienced, in your judgment, the imposition of one or more oackfits, 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.

Response

In the past year, Duquesne Light Company has not experienced the imposition of backfits which would not fit one of the j exceptions listed in 10CFR50.109 (a) (4 ) . However, we would !

i like to comment on possible reasons for this.

a.) The Nuclear Industry is continually and increasingly l implementing its own improvement initiatives. Therefore, l resultant actions taken are industry initiated.

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b.) There are a greater number of utility formed groups working with the NRC Staff today. Consequently, we would expect to have early agreement on resolving issues and to accomplish this in a more economical and practical manner.

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• y L ATTACIIMENT 1 Page 2

4. Please describe any impediments or weaknesses in the backfit process, or in the communications and understanding of that process, and any suggestions for improvements.

Response

The area of estimating the cost asrecin'ced with backfits needs substantial. improvement. An example which is indicative of the prcblem is the controversy over cost estimates relating to the performance of the Individual Plant Evaluation (IPE).

These discussions are recorded for the IPE workshop in Fort Worth, Texas on February 28, March 1 0 2 of this year.

(Reference pp. 123, 132 and 133 of the workshop transcript).

The implications are that the estimates are low when considered on the average and extremoly low when considered for a utility with little experience in risk assessment work.

The discussions at the Workshop also show that the burden which is being estimated must be clearly identified and that all costs should be considered.

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ATTACHMENT 2 l

COSTS FOR 1984 ISSUES NRC Bulletin 88-01 Inspection of Westinghouse DS-416 Reactor Trip Breakers NRC Bulletin 88-01 requested information for three categories concerning the cost of complying with the Bulletin. We provided thac information in the format requested in the Bulletin by two submittals to the NRC. The sum of the costs for the tnree categories is provided below.

(1) Staff time to perform requested inspections, corrective actions and associated operability testing - 94 manhours.

(2) Staff time to prepare requested documentation - 50 manhours.

(3) Additional cost incurred as a result of the inspection findings (e.g., cost of corrective actions, cost of down time) a) Approximate cost of four replacement pole shafts and materials - $6,500.

b) Cost for vendor surveillance - $2,400.

c) Time to install the shafts end do required testing per four breakers - 128 manhours.

NRC Bulletin 88-02 Inspection of Several Models of Westinghouse i

Steam Generators for Evidence of Tube Denting i

Because of Vendor supplied services for the evaluation of the Bulletin 88-02 and the proprietary nature of certain information, we are providing an overall estimate of costs and only on an approximate basis. For each Unit, the costs exceed $100,000.

NRC Lulletin 88-05 Purchasing and QA of Nonconforming Material l Supplied by Piping Supplies, Inc. and West Jersey Manufacturing Company.

Final total costs are incomplete at this time. However, cost estimates, which are thought to be conservative, for purchase reviews and evaluations only, are on the order of 5600 man-hours.

. ec ATTACHM.ENT 2 COSTS'FOR 1988 ISSUES Page 2 Generic Letter 88-01 Replacement of Cracked BWR Piping The ' Beaver Valley Power Station Units 1 and 2 (BVPS-1 & 2) are PWR's. Therefore, the Generic Letter 88-01 does not apply to the BVPS-1 & 2.

i Generic Letter 88-03 Monitoring of AFW Pumps for Possible Backleakage Which could Lead to Steam F Jing Our response to Gr eric Letter 88-03 provided an estimate of approximately. ten hours to review, prepare, and. submit the response. The actions, which Generic Letter 88-03 requested confirmation of, were previously completed to meet NRC Bulletin 85-01 concerns. The review of our investigation into the concerns of Bulletin 85-01 determined that BVPS-1 & 2 had procedures ,

in-place which addressed the concerns. Hardware modifications '

were not incurred as a result of the Bulletin. It is noted that  !

BVPS-1 was not listed for action in the Bulletin. Also, it is noted, that steam binding of auxiliary feedwater pumps was previously addressed by the NRC Information Notice 84-06.

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