ML19347B531

Comments on Ltr to All Licensees of Operating Plants & Applicants for OLs & Holders of Cps. Recommends re-examination of Implementation Schedules for Plants Approaching OL or in Operation

ML19347B531
Person / Time
Site:	Marble Hill
Issue date:	10/06/1980
From:	Shields S PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
NUDOCS 8010150296
Download: ML19347B531 (3)

Text

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Ed7 PUBLIC SERVICE INDIANA October 6, 1980 S. W. Shields Senior Vice Presdent -

Nuclear Division Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commiss1on Washington, D. C. 20555

Dear Mr. Eisenhut:

The intent of this letter is to provide written comments with respect to the report, Letter to All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits, dated September 5, 1980. We understand that the report is considered to be clarification of some of the TMI Action Plan requirements, but is not yet final. Written cecments were requested during September 21 Region III meeting in Chicago.

It is alsc our understanding that the cccments are needed on a timely basis for liRC staff consideration prior to going before the Ccemissioners.

As you know, the requirements and recommendations which have been for=ulated thrcugh studies of TMI have found the form of various reports and letters, and an understanding of their intricacies has been difficult for most involved.

Public Service Company of Indiana, Inc. (PSI) does not..have the same schedule constra*.nts as many other nuclear utilities, as our first two units are not scheduled to be complete until 1986 and 1987. We believe the compilation of TMI related requirements in NURE6s 0660 and 0694 (NRC Action Plan as a Result of the TMI-2 Accident and TMI-Related Recuirements for New Operatinr Licenses),

and now the September 5 letter, is a good practice which should be continued.

Basically we feel the report represents some good thinking. From what we heard at the S;:ptember 21 meeting, plus from others in the industry, there has been difficulty on the part of licensees in meeting some TMI-2 Action Plan subtasks on schedule. The licensees have been at work on the items, and have encountered problems in procurement and construction in some cases, b o\5ot ,

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P.O. Box 190, New Washington, Indiana 47162 812. 293.4441

e Mr. Darrell'G..Eisenhut. October 6, 1980 l 'The September 5 docum'ent.has accordingly factored this, plus some other problems fato new schedules for some of these tasks (as examples, the installation' deadlines for reactor coolant system vents has been moved back-12 months, to January 1, 1982; and the completion date for emergency support facilities has been moved back 15 months, to April 1, 1982). Also we' note that the NRC staff has further defined what is needed to meet some of the tasks, and new: activities have been proposed for some subtasks.

. There were ' additionally some "disj oints" which' have been recognized, the specifics of which were. pointed out in the meeting. Generally, they fell into 1

the following types of areas:

o Some licensees have already ccmpleted designs and installations.

New requirements for them might in effect penalize them for making j the previously established schedules, as retrofits may be required.

o The NRC apparently has'not been able to support'the licensee efforts

with. respect to submittal review. In some-cases,.the required dates for installation may occur before the NRC has initiated review.

o Some of the recommendations which were used as input to the TMI-2 Action Plan sounded very good; however, there is now concern whether.

the necessary instruments and systems can be adequately developed in L support of Lthe required schedules. (One example concerns the require-ment for t'ae installation of an instrumentation system which gives the cont ol room operator a clear, unambiguous indication of inadequate L core cocling; Task II.F.2.. Both the completion of the development 3

program:and the required installation have the same scheduled date:

January 1,'1982. . PSI has-doubts whether such an instrument has been j or can be adequately ' defined) .

l o For operating plants, implementation schedules for activities which would require major reactor shutdowns should take into account

]- individual plant refueling schedules. ,

o In some cases, concern was expressed over additional proposed act-

, ivities that were not accompanied by ' relaxed schedules. (We I

recognize that schedule adjustments are not always necessary) .

We have one general concern: We feel that the implementation schedule for some of the requirements. is-very tight for plants approaching operating

-license or in' operation. We appreciate the pressure that the NRC is.under to get_the.TMI le' sons s implemente'd. ~Nevertheless, we recommend that a re-examination of the required schedules be'made in order to fully define the; required systems and_their respective contributions to overall plant 4- safety.

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.. I Mr.lDarrell G. Ein nhut- ~ Octobsr 6, 198G-Again, please continue the practiice of accumulating the current status of

. requirements into one document. . We would be pleased to discuss this or any

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other of our comments with you 1f you wish.

Since ly,

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S. W. Shields RSW:gb-2 l

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