ML19347E629
| ML19347E629 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/08/1981 |
| From: | Selby J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 12176, NUDOCS 8105130153 | |
| Download: ML19347E629 (2) | |
Text
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J D Selby
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Cbderwean of the Board sud President s
General offices: 212 West Michigan Avenue, Jackson, Michigan 49201 + (517) 788-1600 May 8, 1981 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission s
Washington, DC 20555 MIDLAND PROJECT PROJECTED LICENSING SCHEDULE FILE: 0505.2 UFI: 70*01 SERIAL: 12176
Dear Mr. Denton:
On January 16, 1981, I wrote a letter to John Ahearne, then Chaicman of the NRC, expressir.g my concern with regard to NRC's projected licensing schedule for the Midland Plant as given in NRC's November 21, 1980 Status Report to Congress. Your response of February 10, 1981 stated that a reexamination of facilities such as Midland with construction completion dates beyond CY 1982 was in progress. 16 addition, you indicated that upon completion of the re-examination you would provide me with the results and a description of the effect on Midland 2.
Recently we received a copy of NRC's March 31, 1981 Status Report to Congress.
Table 2 of that report, while indicating an MRC decision date of 7/83, in agreement with our current Midland 2 fuel load date, retains the NRC's previously scheduled SER dato of 7/82. Thus, the post-SER licensing duration has been further shortened and this duration of one year has been applied to all units scheduled for completion during CY 1983.
I continue to believe that the NRC's scheduled SER issue date for Midland is unrealistic and places undue pressure on the post-SER licensing process. In particular an ACRS (SER-SSER) duration of only one month is not reasonable for Midland. Likewise, experience in the past with heavily contested hearings on Midland indicates the need for a longer than average hearing duration.
As stated in my March 2, 1981 response to your letter of February 10, 1981, I support the establishment of realistic schedules and proper prioritization for all plants. Thus, I am pleased to note in the March 31 Status Report that the Staff is attempting to reconcile the discrepancies between NRC and applicant construction completion dates.
In this regard, recent Midland construction progress is demonstrating the required installation rates to achieve our over-all construction schedule.
In fact, during the past five weeks ending April 26, the project installed 738,000 ft of wire and cable and also exceeded scheduled 300 /
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A Mr. Harold R. Denton May 8, 1981 2
quantities of other critical commodities such as conduit, small pipe and small pipe hangers. We are confident that there is a sufficient engineering backlog to sustain the required installation rates. We also believe, subject to Staff review, that our design is based on a realistic scope thct properly incorporates the post-TMI issues. We feel that our current progress is indicative that our planned Unit 2 fuel load date of July 1983 is attainable.
I am also encouraged by an increased amount of licensing review activity by the Staff on the Midland docket, particularly the Staff participation in the Design Review Board meeting on Cold Shutdown and a subsequent Auxiliary Feedwater technical review meeting in late April. The critical nature of the Midland licensing schedule dictates the need for additional similar meetings as well as other alternative review techniques, as appropriate; and I request your continued positive response to our initiatives in this regard.
Nevertheless, I believe that the Midland licensing schedule presented in Table 2 of NRC's March 31, 1981 Status Report to Congress represents an unacceptable risk to Consumers Power, its customers, and its stockholders in terms of the likelihood of our obtaining a license to load fuel in Unit 2 upon completion in July 1983. NRC Chairman Hendrie stated on P. 4 of that report that the Table 2 " schedules are based on completing the licensing process prior to the applicant's estimated construction completion date."
I request that you reassess the realism of the NRC's current licensing schedule for Midland and, specifically, that you consider advancing the schedule for issuance of the Midland SER by six nonths to January of 1982. My staff at Consumers Power is available to support the NRC staff in any way you consider appropriate to
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attain this more realistic licensing schedule.
Yours very truly,
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U p/. D. Selby JDS:im
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