ML20003A814
| ML20003A814 | |
| 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) |
| References | |
| NUDOCS 8102090095 | |
| Download: ML20003A814 (1) | |
Text
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January 16, 1981
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The Honorable John F Ahearne, Chairman qp US Nuclear Regulatory Commission
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Dear Chairman Ahearne:
The purpose of this letter is to express cur' 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 Appropriaticas 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-l mcat 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, for l
Unit 2 and Unit 1, respectively, and the corresponding NRC Caseload Forecast Panel projections of October 1983 and April 1984.
DS63 These end dates are accurately presented in Attachment 4, Table 1, of your S
Status Report to Representative Bevill. However, while we conctr <ith the j
assumption of a heavily contested hearing for Midland, we strongly disagree g
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 testi=eny.
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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We are concerned that the current unrealistic post-SSER durations will lead to delays in issuing SERs and ultimately result in delaps 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
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beyond completion of construction.
We continue to believe that a relatively higher review priority is justified for Midland based on the acknowledged 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 informed of the Commission's detailed licensing schedule for Midland indirectly via the NRC submittal to Congress.
Nevertheless, the potential consequences are so grave that we urge the Commission to carefully ensider 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,
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