ML20005A333
| ML20005A333 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/25/1981 |
| From: | Selby J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 12788, NUDOCS 8106300201 | |
| Download: ML20005A333 (3) | |
Text
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J D Selby Chairman of the Board and President
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oeneral offices: 212 West Michigan Avenue, Jacitson, Michigan 49201 + (517) 788-16o0 3
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June 25, 1981 rms
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Mr. Harold R. Denton, Director
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US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND PROJECT PROJECTED LICENSING AND CONSTRUCTION SCHEDULE DOCKET NOS 50-329, 50-330 FILE: 0505.2 UFI: 70*01 SERIAL: 12788
Dear Mr. Denton:
This letter is in response to your June 9, 1981 requn t to confirm or change our construction completion dates for the Midlan6 Ph:It. As noted in J' W.
Cook's letter of August 22, 1980, the Company's 1.cn estimate of the construction completion dates ie, the fuel load dates, for the Midland Plant, Units 1 and 2 are December 1983 and July 1983, respectively. The NRC caseload forecast panel review, as documented in an NRC meeting summary dated September 16, 1980, resulted in a finding of reasonable agreement with the Consumers Power Company (CP Co) projected construction completion dates. Our confidence in these dates has been supported by recent progress in achieving l
bulk commodity installation rates that exceed scheduled installation rates and l
by maintenance of sufficient engineering backlog to sustain these rates. As I l
indicated in my May 8, 1981 letter, the Midland construction effort continues l
to demonstrate the required progress necessary to achieve our overall construction schedule.
Although Table 2 of your June 9,1981 letter accurately reflects our projected construction completion date, the associated licensing schedule does not adequately support a timely NRC decisica on an operating license. As I stated in my May 8, 1981 letter and as we subsequently discussed in our telephone convecsation of June 18, 1981, we believe that.he NRC's scheduled SER issue date for Midland is unrealistic and places undue pressure on the post-SER l
licensing process The application of an assumed standard int._ val of 11 months from issuance of SSER to the NRC decision date is inappropriate for plants anticipating heavily contested hearings. Based on our review of actual el oc0681-0075b131 6
8106 30 0 W A
Mr. Harold R. Drnton June 25, 1981 2
and proposed changes to the licensing regulations, NRC reports to Congress and licensing experiences at_ Midland and other plants, CP Co anticipates the following Midland durations:
o SER to SSER including ACRS (3 months) o SSER to beginning of hearings (5-6 months) o hearing duration (6-8 months) o hearing completion to all proposed findings filed (2 months) o findings filed to licensing board decision (1-2 months) and o licensing board decision to Commission decision (1 month)
This assessment implies a minimum of 18 months from SER issuance until a Commission decision.
I continue to believe that an immediate higher review priority is justified for Midland based on this licensing schedule assessment, the realism of our current scope and schedule, the OL application docket date of November 1977 and approximately 16 months of NRC Staff review prior to TMI, and the unique cogeneration aspect of the facility.
I do not believe it is necessary to wait until the Commission completes its consideration of proposed changes to its regulations before you re-examine our relative priority. While we encourage your efforts to improve licensing durations, we still conclude that nothing proposed by the NRC to date will substantially reduce the likelihood of an SER to NRC decision duration or at least 18 months for Midland.
Furthermore, the recent Statement of Policy on Conduct of Licensing Proceedings is to a great extent dependent for its success on mutual cooperation of the participants. Such a situation is not common in heavily contested hearings.
If our priority and licensing schedule are not quickly reexamined, it will be too late for the NRC to allocate the proper internal resources to support the necessary January 1982 SER issuance date.
Therefore, the review windows established as a result of your June 9, 1981 letter must quickly and accurately reflect realistic construction completion dates as well as anticipated post-SER licensing process durations.
In this regard I have noted.n your earlier November 21, 1980, Report to Congress that the only CY 1983 plants that are expected to be heavily contested are Midland and Seabrook. A review of the schedules published in the May 29, 1981, NRC Report to Congress indicates that Seabrook construction completion has recently been delayed by 10 months while the NRC maintains the same review window, allowing 22 months from SER to construction completion.
It was also indicated in your June 9, 1981 request that Seabrook's FSAR had not yet been submitted. At the same time Midland, which should receive a higher review priority for reasons stated above, is assigned an SER date which is six months later and an overall licensing schedule which is unreasonably short for a heavily contested plant. Therefore I conclude that unless other CY 1983 plants report either an improved construction ccmpletion date or that they anticipate hearings contested at a level similar to Midland, Midland should be scheduled for a January 1982 SER issuance.
In closing, I would like to reaffirm our belief that the Midland ?ocket is substantially complete and would support more extensive NRC review. You should also be aware that Mr. R. W. Huston of Consumers Power Company is oc0681-0075b131
Mr. Harald R. Denten June 25,1981
.3 currently located in Bethesda to ensure close contact between NRC Staff and our technical experts during all stages of the licensing review and SER development process. In addition, we are prepared to have whomever on our staff is required in Bethesda to work with the NRC Staff in the final stages of SER development. As a result of the procedural changes to operating license reviews, it is our understanding that NRR will issue a single set of Midland questions in July of 1981. This new approach combined with the allocation of more Staff reviewer resources should make it possible to achieve a January 1982 SER. My staff at CP Co is available to support the NRC Staff in any way you consider appropriate to attain this goal.
I look forward to close cooperation during this crucial period and, as requested, will provide quarterly updates until issuance of the SER.
Ycurs very truly, t
J. D. Selby l
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