ML20247L576

Forwards Response to 890407 Backfitting Questionnaire.Most Significant Weaknesses in Backfit Process Include Identification Process & cost-benefit Analysis.List of plant-specific Implementation Costs Also Encl

ML20247L576
Person / Time
Site:	Callaway
Issue date:	05/24/1989
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-GTECI-093, REF-GTECI-NI, TASK-093, TASK-93, TASK-OR GL-88-01, GL-88-03, GL-88-1, GL-88-3, IEB-88-001, IEB-88-002, IEB-88-005, IEB-88-1, IEB-88-2, IEB-88-5, ULNRC-2010, NUDOCS 8906020207
Download: ML20247L576 (6)

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'$1 May,24, 1989 U.S. Ndclear Regulatory Commission 1 Attn -Document Control Desk Mail Station Pl-137 Washington, D.C. 20555.

Gentlemen: ULNRC 2010 t

DOCKET. NUMBER 50-483 CALLAWAY PLANT

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BACKFITTING QUESTIONNAIRE

Reference:

' Letter dated April 7, 1989 from E. L. Jordan, NRC to All Licensees of

. Operating Reactors Attached is Union Electric's response to the questionnaire'provided in the Reference. In' addition, a table is included which gives approximate imple-mentation. costs incurred at Callaway Plant to complete the items identified in the Reference as 1988 backfit issues. Union Electric-believes-the effective imple-mentation of the backfit procedures is.an essential element of the management of the regulatory process.

Therefore, we are pleased to see that the NRC manage-ment is interested in the~ Licensee's views on the effectiveness of the process.

Please contact me or Mr. D. E. Shafer'of my' staff if you have any questions regarding the attached response.

Very truly ours, Donald F. Schnell JMC/pkn-Attachment I

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-Shaw,fPittman, Potts & Trowbridge

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,Dr . nI. O.-Cermak CFA,.Inc.

41 Professional Drive (Suite 110).

Gaithersburg',' MD ~20879 Ri C[ Knop

' Chief,LReactor; Project' Branch'l

.U.S.? Nuclear. Regulatory ~ Commission-

. Region III!

799 Roosevelt-Road Glen (Ellyn, Illinois 60137' i

Bruce lLittle: ..

1 Callaway Resident Office  ;

U.S.l Nuclear" Regulatory Commission. i RR#1! ,

Steedman,. Missouri 65077  ;

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' ' Tom Alexion (2)

Office of Nuclear Reactor Regulation U.S.. Nuclear Regulatory Commission .;

i l' White F. lint, North, Mail Stop 13E21 11555 Rockville Pike Rockville, MD 20852-Manager, Electric Department l Missouri Public Service Commission j P.O. Box 360 -g

-Jefferson City, MO 65102

-U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-

. Edward L. Jordan, Director i Office for Analysis and Evaluation -)

of Operational Data U.1S. Nuclear Regulatory Commission 7735.01d Georgetown Road Bethesda, MD 20814- .

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Nuclear Date E210.01 DFS/ Chrono D. F. Schnell J. E. Birk J. V. Laux M. A. Stiller G. L. Randolph R. J. Irwin-H. Wuertenbaecher W. . R. Campbell-A. C. Passwater R. P. Wendling D. E. Shafer D. J. Walker.

O. Maynard (WCNOC)

N. P. Goel (Bechtel)

T. P. Sharkey NSRB (Sandra Auston) 4

• Attachment to ULNRC -

Page 1 of 3 Question 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 to Ouestion 1

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Union Electric believes the current NRC procedure is sufficiently clear and effective on how backfits are processed once they have been identified. However, Union Electric does not believe the procedure is sufficiently j clear and effective on how backfits are identified.

Question 2 Is NRC 8taff practice consistent with the 0514 process in identifying and implementing backfits? If not, would you please comment on any specific observed inconsistencies?

Response to Ouestion 2 Union Electric believes the NRC staff practice is consistent with the 0514 process in identifying and implementing backfits.

Question 3 In the past year have you experienced, in your judgement, 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.

Response to Ouestion 3 During the past year Union Electric has not experienced the imposition of any backfits that could be categorized by this question.

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

4

Attachment to ULNRC -

. Page 2 of 3 Response to Question 4 The two most significant weaknesses in the backfit process are the identification process and the cost benefit analysis. The direct and indirect costs of implementing the backfit must be justified in view of the increased protection provided. This analysis is extremely difficult to perform and requires considerable judgement and a number of assumptions. These analyses are typically performed by individuals with incentive to show that a change is needed. More objectivity and perhaps some industry input could improve the cost benefit analysis.

...J Attachment to'ULNRC - l

. Page 3 of 3 )

- i t-

. j TABLE OF PLANT SPECIFIC IMPLEMENTATION COSTS  !

L' Issue Approximate Cost l

1. NRC Bulletin 88-01 (Defects in $33,500 Westinghouse Circuit i Breakers) j

2. NRC Bulletin 88-02 (Cracks in Steam

• Generator Tubes)

3. NRC Bulletin 88-05 (Nonconforming PSI and $100,000 WJM Materials)

4. Generic Letter 88-01(NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping)

5. Generic Letter 88-03 (Resolution of Generic $2,000 Safety Issue 93,

" Steam Binding of Auxiliary Feedwater Pumps")

• Minimal review costs incurred, issue was determined to be not applicable to Callaway Plant.

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