ML19351G442
| ML19351G442 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/16/1981 |
| From: | Selby J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Ahearne J NRC COMMISSION (OCM) |
| Shared Package | |
| ML19351G440 | List: |
| References | |
| NUDOCS 8102230713 | |
| Download: ML19351G442 (2) | |
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C0mpEy ca- **8" and Presndent Generet offices: 212 Vuest Michigan Avenue, Jackson, Michsgan 49201 *(517) 788-1600 January 16, 1981 The Honorable John F Ahearne, Chairman US Nuclear Regulatory Commission Washington, DC 20555
Dear Chairman Ahearne:
The purpose of this letter is to express our deep concern with regard to the content and potential impact of the NRC Status Report dated November 21, 1980, to Congressman Bevill, Chairman, Subcommittee on Energy and Water Development, Committee on Appropriations, US House of Representatives. This report was generated in response to House Report 96-1093 regarding the Energy and Water Development Appropriations Bill for FY 1981.
On Page 12 of the Status Report it is stated:
The Staff has recently (October 1980) reassessed the target mile-stone dates provided with the April 17, 1980 testimony in order to include, more realistically, additional time for public hearings and subsequent Commission action, and also to consider any changes in the projected construction completion dates for the various facilities.
Consumers Power Company (CP Co) actively participated in the Staff reassess-ment of the Midland Plant, providing extensive information to the NRC Caseload Forecast Panel during the summer of 1980.
In addition, several meetings were held between CP Co and NRC Staff management concerning timely resumption 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 be-tween the CP Co scheduled fuel load dates of July 1983 and December 1983 fer Unit 2 and Unit 1, respectively, and the corresponding NRC Caseload Forecast Panel projections of October 1983 and April 1984.
These end dates are accurately presented in Attachment.4, Table 1, of your Status Report to Representative Bevill. However, while we concur with the assumption of a heavily contested hearing for Midland, we strongly disagree with the assumption of a hearing duration of only four months used for projecting target schedules for heavily contested hearings. This assumption is not justified on the basis of previous and current experience and contra-dicts the introductory statement cited above since realistic additional time for public hearings has not been provided in the current schedules relative to the April 17, 1980 testimony.
In the case of Midland, the new NRC schedule reflects an overall decrease in the duration from SSER to OL issuance.
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2 Ve are concerned that the current unrealistic post-SSER durations will lead to delays in issuing SERs and ultimately result in delays of plant start-up.
There is the clear implication in the NRC report to Congress that the number of impacted plants as measured by delay in OL issuance beyond construction completion will extend far beyond the 5 units currently projected as being delayed 3-10 months in Attachment 4.
If this should occur, it would create severe adverse consequences for Consumers Power, numerous other utilities, and the country as a whole.
Based on our Midland schedule analysis, the current NRC schedule for issuing an SER could result in a 10-month licensing delay beyond completion of construction.
j Ve continue to believe that a relatively higher review priority is justified for Midland based on the acknowled;ad realism of our current project scope and construction schedule, the OL application docket date of November 1977 and approximately 16 months of NRC Staff review prior to TMI, the fact that this is the lead OL application utilizing a B&W NSSS, the recognition of procedural and intervenor impact on post-SSER licensing activity schedule durations, and the unique cogeneration aspect of the facility.
In a December 10, 1980 letter to Harold Denton, we outlined our ongoing efforts to facilitate Staff resump-tion of the Midland docket review.
We regret, considering our extensive interaction with the NRC Staff on this subject over the past year, that we were 6 informed of the Commission's detailed licensing schedule for Midland indirectly via the NRC submittal to Congress.
Nevertheless, the potentia' consequences are so grave that we urge the Commission to carefully consider the basis for the assumptions utilized in Table 1 and, in particular, the overall licensing schedule currently projected for the Midland Plant.
Yours very truly, 4
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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 resumption of formal docket review of the Midland Plant.
As noted in the NRC minuter, 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 tne 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 the staff's 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,tnese iaeas ano others ano tne Dalance or, tnis letter is"a 'tatus reporton these s
activities.
In the Post-TMI time franie most nuclear plant projects have been reassessed and ' he majority have already deterinined significant impacts on completion t ~
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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 l
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 earlv 1980 was but one facet of this ef fort.
Even prior to the project reorgan ation the' Consumers Power Midland Nuclear Safety Task
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Force utilized a formal task description and recommendation process to coordinate the resolution of major pre-TMI open itecs identified by the NRC staff and to determine the Midland specific response to post-TMI issues and l
events. These efforts were formally documented in Revision 30 to the l
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 d
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 protocol for NRC participation.
In order to assure proper utilization of our limited resources, we shculd personally monitor the progress of this effort to ensure that it is achieving the desired results.
We continue to believe that a relatively 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 revita 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 consictent with construction completion dates.
In particular, based on what we believe is a reasonable projected licensing schedule (See Enclosure 2 of the staff's September 16, 1980 meeting minutes), an SER issuance date in 1981 seems essential to be consistent with the schedule analysis of both our organizations.
In conclusion, the eJfort outlined above hopefully conveys Consumers Power Company's commiteeut to facilitate resumption of the Midland docket review.
Cooperation in these efforts is essential to timely completion of the NRC staff review.
I would appreciate receiving your comments on our proposal oc1180-0094a100
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and would also like the opportunity to meet with yod periodically to review i
the progress of our licensing review.
In the meantime we will pursue thic l
approach in detail with your staff.
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CC JDSelby RJCook, Resident Inspector GSKeeley MMiller, IL&B TJSullivan l
FPCowan, Hearing Board Member
.GLinenberger, Hearing Board Member CBechhoefer, Hearing Board Chairman d.
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