ML19345D665
| ML19345D665 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/10/1980 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8012160443 | |
| Download: ML19345D665 (3) | |
Text
D James W Cook Vuce PresiJent - Projects, Engsneenng
.tnd Constructson c.n.ral offices: 1945 W.st Parnall Road, Jackson, MI 49201 *(517) 788-o453 December 10, 1980 15
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y Harold R Denton, Director M
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US Nuclear Regulatory Commission Washington, DC 20555 This letter is in response to the June 13 and August 25, 1980, meetings between CP Co and NRC management concerning timely recumption of formal docket review of the Midland Plant. As noted in the NRC minutes of these meetings issued September 16, 1980, there is reasonable agreement between the CP Co scheduled fuel load dates of 7/83 and 12/83 for Unit 2 and Unit 1, respectively, and the corresponding NRC Caseload Forecast Panel projections of 10/83 and 4/84. However, I note with some dismay the statement in the meeting minutes that the staff's still to be announced licensing schedule "may not necessarily coincide with the construction completion date."
If this should occur, it would create severe adverse consequences for Consumers Power and would be a direct reversal of the NRC's stated objectives of completing the licensing process coincident with the completion of the construction process. Recognizing tha aff's
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resource constraints, it is imperative that we take steps now to allow timely resumption and efficient completion of Midland docket review.
At our August meeting, you made certain suggestions on how we might assist in moving the Midland Licensing process forward. We have pursued these toeas ano others ano tne Dalance or tnis letter is a status report on enese a c tiVitie's.
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la the Post-TMI time frame most nuclear plant projects have been reassessed and the majority have already determined significant impacts on completion
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dates based on current requirements. Consumers Power Company was among the first to publicly recognize the current realities and has taken significant steps to focus all the Company's technical and financial resources towards the expeditious completion of the plant. The reorganization of the Midland Project in early 1980 was but one facet of this effort.
Even prior to the project reorganization the' Consumers Power Midland Nuclear Safety Task Force utilized a formal task description and recommendation process to coordinate the resolution of major pre-TMI open items identified by the NRC staff and to determine the Midland specific response to post-TMI issues and events. These efforts were formally documented in Revision 30 to the Midland FSAR submitted in October 1980. An updated Security Plan and associated documents along with Revision 11 to the Midland Environmental Report have also been submitted recently.
In addition the revised Site Emergency Plan is scheduled for submittal this month.
In summary, the application is ready for post-TMI review.
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We continue to monitor the evolution of requirements for more explicit documentation of compliance with regulations.
In particular we have undertaken a review to assure that Midland positions on the General Design Criteria and applicable Division 1 Regulatory Guides are sufficient to meet our understanding of the staff's needs, and we stand ready to expand this effort as specific requirements are established. As mentioned above, we have presented Midland positions on pre-TMI open items and post-TMI issues and events in Revision 30.
We have also undertaken a probabilistic risk assessment of the Midland Plant to support overall safety decision making and, where appropriate, to assist in the justification of acceptable alternative approaches to NRC staff interpretive documents.
In conjunction with the above efforts and in view of your stated willingness to provide NRC staff participation in final design review meetings on critical issues, we will contact our NRC Project Manager to arrange with the staff for such participation on a trial basis. Such meetings are a logical conclusion to ongoing design review meetings and provide an opportunity to review critical design aspects and compliance with applicable design, availability, safety, and licensing requirements.
These meetings will now have the added benefit of NRC participation with a resulting increase in the NRC staff's understanding of critical design issues. Meeting minutes are utilized to document major points of discussion and action items. Action items are resolved within the context of our existing design change control program. Our staffs should work to establish the protocc1 for NRC participation.
In order to assure proper utilization of our limited resources, we should personally monitor the progress of this effort to ensure that it is achieving the desired results.
We continue to believe that a r latively higher review priority is justified for Midland based on the realism of our current scope and schedule, the OL application docket date of 11/77 and approximately 16 months of NRC staff review prior to TMI, and the unique cogeneration aspect of the facility. We encourage more NRC staff participation in appropriate forums for the review of the Midland docket. We also encourage the use of NRC contractors if lack of staff resources leads to projection of an OL issuance date which is not consistent with construction completion dates.
l In particular, based on what we believe is a reasonable projected licensing schedule (See Enclosure 2 of the staff's September 16, 1980 meeting i
minutes), an SER issuance date in 1981 seems essential to be consistent with the schedule analysis of both our organizations.
In conclusion, the effort outlined above hopefully conveys Consumers Power Company's commitment to facilitate resumption of the Midland docket review.
l Cooperation in these efforts is essential to timely completion of the NRC I
staff review.
I would appreciate receiving your comments on our proposal I
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t and would also like the opportunity to meet with you periodically to review the progress of our licensing review.
In the meantime we will pursue this approach in detail with your staff.
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CC JDSelby RJCook, Resident Inspector GSKeeley MMiller, IL&B TJSullivan FPCowan, Hearing Board Member GLinenberger, Hearing Board Member CBechhoefer, Hearing Board Chairman 1
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