ML19343C494

Expresses Concern About Lack of Progress Re Facility OL Review.Ser Should Be Scheduled for Completion by Dec 1981 as Util Expects OL Application to Be Subj of Public Hearings. Meeting Requested to Develop Positive Guidance

ML19343C494
Person / Time
Site:	Clinton
Issue date:	03/17/1981
From:	Koch L ILLINOIS POWER CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8103240381
Download: ML19343C494 (3)

Text

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s ILLINOIS POWER OOMPANY

_. . 500 SOUTH 27TH STREET DECATUR. !LLINOIS 62525 March 17, 1981

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Dr. Harold R. Denton, Director Office of Nuclear Reactor Regulation pij y[.f41Eh

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U.S. Nuclear Regulatory Commission 7 ..-'O Washington, D.C. 20555 gg[ ,

Dear Dr. Denton:

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Clinton Power Station Operating License Review Docket No. 50-461 k

j: Ref: Letter, L. J. Koch to Harold R. Denton

-dated August 11, 1980 Last-summer we met in your office to discuss various ways to improve the licensing schedule for the Clinton Power Station. At that time we agreed that the way to accomplish this objective was to employ innovative methods of reviews which would make the most

. efficient use of NRC Staff resources. In this and the subsequent meeting in October -- again in your office -- we discussed specific

-details of such methodsLof. review.

.The purpose of this letter is to advise you that we are con-cerned about the. lack-of progress which has been made'to date, and to urge you- to apply the resources of your of fice to improve '.he Clinton licensing effort. In response to the reevaluation of licensing schedules by the. Commission and their recognition of the

'mpact of public hearings, we believe that the Clinton licensing schedule is even more critical than we ' had estimated.

.Although-the-Licensing Board has'not yet made a determination, we believe that it is necessary to assume, for scheduling purposes,

'that the Clinton operating license application will be.the subject

.lof public hearings. In accordance with NRC estimates of'the schedule i- ~ impact of such hearings, we recommend that the NRC Safety Evaluation

' Report for Clinton be scheduled-for completion-in December 1981.

Even.with this completion date,1 current NRC' experience indicates that-

' issuance of the Clinton' operating license could be delayed until September _of11983~or later. This is nine months beyond our current

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• Dr. Harold R. Denton March 17, 1991 est. mated con

• mction completion date, but with the SER completed, the NRC would e the capability to take steps to adjust the schedule.

In contrast to the above schedule considerations, the current NRC " Status Summary" for the Clinton operating license indicates the SER would be issued 3/82 and the SSER issued 1./S3. Since the Commission is now estimating "15 months from SSER to Commission review of OL's," the Clinton OL could be delayed to 19S4. This would be catastrophic; it would result in a situation in 1983 as bad or worse than exists with completed nuclear plants now. It would result in a cost to our customers of hundreds of millions of dollars.

We are convinced that this kind of delay must and can be avoided.

We recognize that other causes of delay (such as public hearings) can arise which may be beyond your control. We are aware also that actions are being considered by the SRC which could potentially reduce their impact. However, these activities, and related correc-tive actions, will not commence until triggered by MRC issuance of the SER. Therefore, the central objective of the total Clinton licensing plan and strategy must be to issue the SER this year.

We believe that this objective can be met if an aggressive, imaginative licensing plan is adopted. We have proposed actions which we believe would contribute to such a plan. We are prepared to proceed in this manner, and to apply our energies to identifying additional licensing efficiencies.

We have met with members of the Staff and NRC subcontractors to initiate the special reviews which we described in my reference letter as well as subsequent discussions. These reviews wil) encom-pass those new design features which are being reviewed for the first time on the Clinton docket. This process of preparing special descriptions and discussions of the new and unique. features in the Clinton Station is a vital element of our plans to support the NRC licensing effort. However, this program must be accelerated and utilized efficiently to effect the improvements which we believe are possible.

Similarly, we are proceeding to identify those features of the Clinton design which have been previously reviewed by the Staff.

It now appears that this program can be even more effective than we had first estimated. General Electric has completed a comparative evaluation of 'F.e BWR/4, 5, and 6 designs and has found that about 90% of the BWR/6.NSSS is identical to the BWR/4 and 5. As a result,

Dr. Harold R. Denton March 17, 1981 we are prepared to expand our proposal and identify for you the material which has already been closed out on the BWR/4 and 5 applications and whi~h is equally applicable to Clinton. By doing so, the necessity for repetitious evaluation by the Staff can be avoided. This time-sa' ring approach when combined with the applica-tion of responses to the Grand Gulf questions,which we are already doing,should minimize the effort required by the Staff.

The activities described above will require our continuing attention if they are to result in improving the CPS licensing schedule. Consequently, I am requesting a meeting with you and appropriate members of your Staff as soon as possible to develop positive guidance which will assure our objective. The Clinton Licensing Board has scheduled a second pre-hearing conference for April 14, l981. I suggest that we meet the followinc week (week of April 19) so that we may also include the results of that conference in our planning.

We welcome your comments and suggestions in response to these proposals.

Sincerely, 79/

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7-L. J. Koch Vice President cc: J. M. Hendrie, Chairman, NRC C. I. Grimes, Project Manager, Clinton Project, NRC W. R. Smith, President, Soyland Power Cooperative, Inc.

L. W. Aeilts, President, Western Illinois Power Cooperative, Inc.