NRC-91-0016, Comments Supporting NUMARC Comments on Notice of Availability of SECY-90-347, Regulatory Impact Survey Rept. NRC Improvement Plan Is Step in Right Direction in Solving Problems Identified in Regulatory Impact Survey

Comments Supporting NUMARC Comments on Notice of Availability of SECY-90-347, Regulatory Impact Survey Rept. NRC Improvement Plan Is Step in Right Direction in Solving Problems Identified in Regulatory Impact Survey

ML20066J307
Person / Time
Site:	Fermi
Issue date:	01/28/1991
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-91-0016, CON-NRC-91-16, FRN-55FR53220, RULE-PR-MISC 55FR53220-00008, 55FR53220-8, MISC-90-10, NUDOCS 9101310072
Download: ML20066J307 (3)

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January 28, 1991 NRC-91-0016 f

U. S. Nuclear Regulatory Commission Attn: Docketing and Service Branch

.... Washington, D. c. 20555 Referen;es: 1) Permi 2 NRC Docket No. 50-341 NRC License No. NPT-43

, 2) SECY-90-347. " Regulatory Impact Survey Report", a dated October 9. 1990

Subject:

Comments on SECY-90-347,.." Regulatory Impact Survey Report" Detroit Edison has revicwed SECY-90-347, " Regulatory Impact Sut'ey Rep ort" .' We applaud the Nuclear Regulatory Commission for initiadng action in response to the Regulatory Impact Survey and for providing the opportunity for public comment. Detroit Edison endorser NUMARC's general comments on SECY-90-347 and additionally would like you to consider the following comnents.

In general. the NRC. improvement plan is a step in the right direction

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in solving the problems identified in tho' Regulatory Impact SutNey.

Nowever. it does not go .far enough in addressing the areas of informal' requirements. NRR staff enhancements and reasons behind lisensee acquiescence to NRR x4 quests. We endorse the NUMARC comments on the latter item, so this letter vill address the first two items while >

discussing specific comments on the three areas the NRC has targeted for action.

In the area of managing the effect of cumulative requirements and generic communications. Detroit Edison agrees an integrated schedu'.e -

is a good starting point. The NRC's plan to stabilize advanced .

planning of regulatory requirement implementation will be beneficial considering the long lead time needed for effective engineering, work planning and parts procurement for plant modifications. We have developed a 5 year operating plan which includes major modifications and other projects including NRC mandated. NRC committed and self-initiated items. To be effective all these items need to be included. To prevent inef fective use of resources. items from any source should be dropped if their priority, including their 9101310072 910128 )

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'd safety-benefit, are low. For NRC mandated and committed activities, consunication of deletion of these items should be conducted, but the NRC needs to be open to the elimination of such items so that resources can be most effectively used. Also, the NRC should review existing prioritization and scheduling schemes in developing their guidance. We would be happy to criteria for your consideration. provide a copy of our prioritization A last comment on the topic of generic requirements and communications is that the NRC should closely evaluate the use of the adequate protection standard. Items meeting the adequate protection criteria are trot further avai.uated for cost / benefit considerations and per SECY-90-347 would not be eligible for prioritization review. At the Region III backfitting workshop, attendees expressed the opinion that the adequate protection criteria is overused in generic communications. We share that opinion.

Ragarding scheduling and control of inspections. Detroit Edison is happy that the NRC now recognises the large Lepset team inspections have on licensees. However. 4 team inspections within a year would still cause an extremely heavy impact on a plant. Typically. at leset one employee is tied up during the inspection per inspector plus department heads and senior management are greatly involved.

Additional resources are used in followup activities. No more than team inspections per sear should_ be the threshold for the additional 5 review and approval.

Detroit Edison endorses the NRC plan to announce significant NRC site activities. We request that the NRC also consider planned refueling outages in developing inspection schedules. The necessary extensive demands on personnel during a team inspection are more dif ficult to handle when plant personnel are already extremely buey during a refueling outage.

The laet area the NRC has targeted for action is training, preparation and management of NRC staf f. The majority of actions in this area are aimed at inspectors. These actions are very important. However. many of these initiatives wculd serve to improve the professionalism and consistency of performance among all NRC personnel. not just inspect ors. The backfitting

• raining being given for both regional and NRR staf f is a good example of an action that will benefit both the NRC and utilities by creating common understanding of the backfit rul e. This, hopefully, will also reduce the number of informal requirements that NRC personnel, regional, site, and headquarters, attempt to promulgate. These informal requirements, which are sometimes tied verbally to dALP scores, can engage conside.sble plant resources whether the plant acquiesces or disagrees. Retresher training or discussions in the areas of backfitting and man 4gement expectations would niso be he'.pful to keep NRC personnel focused in

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USh7,C January 28. 1991 hRC-91-0016 Face 3 the direction management expects and to prevent recurrence of some of tbs problems identified in the Regulatory Impact Survey.

'"ollowing the discuccions of the three major improvetoent areas.

SECY-90-347 discusses other comment topic areas. One of the areas discussed is improved Technical Specifications. We are growing concerned at the continued delays in the issuance of the draf t SER and whether the approved Technical Specifications will be so different from wh.t was proposed as to negate the benefits of the improvements.

To achieve the industry-wide benefite that were the original goals of this program. the approved version of the improved Technical Specifications has to be something the licensees are villing to adopt or this large NRC and licensee effort will have been in vain.

In the discussion on event reporting. SECY-90-347 mentione that the NRC staf f is considering making a revision to 10CFF.50.72 and 50.73 to eliminate unnecessary reports of certain engineered safety features.

' Eetroit Edison strongly agrees with this idea. Eliminating unnecessary reports on such " events" as scram signale when the reactor is shutdown and cleanup system isolations will save both URC and licensee resources that can be used more effectively elsewhere. The primary f ocus of changes to event reporting regulations should be on the safety significance of events being reported. This focus le being subodied in guidance under development by the BWK Owner's Group.

Detroit Edison has been actively participating in this effort.

In conclusion. Detroit Edison generally agrees with the actions discussed in SECY-90-347 but thinks additional steps are necessary to more fully address the problems identified by the Regulatory Impact Survey. If you have any questions or would like to discuss any specific comment, please contact Lynne S. Goodman at (313) $86-4211.

Sin ce rely.

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