ML20032B842
| ML20032B842 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/30/1981 |
| From: | Thorpe J JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0485, RTR-NUREG-485 NUDOCS 8111060434 | |
| Download: ML20032B842 (2) | |
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Jersey Central Power & Ught Company Madison Avenue at Punchbowl Road Morristown NewJersey 07960 201 539-6111 October 30, 1981 Harold R. Denton Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Denton:
Subject:
Oyster Creek Nuclear Generating Sterion, Systematic Evaluation Program The purpose of this letter is to present JCP&L's responses to and commente on the NRC's plans and schedule f or completion of the Systematic Evaluation Program (SEP). These plans were described in discussions between NRC and JCP&L representatives at Oyster Creek on September 17, 1981. The NRC's draft schedule for completion of the SEP (NUREG-0485 dated July 31, 1981) was also given to us at the September 17th meeting. Based on these discussions and the NRC's draft schedule, it is our inderstanding that the main steps and schedule planned for completing the Oyster Creek Saf ety Evaluation Report (SER) on the SEP are as foilows:
- Complete integrated assessment by the Staff and issue the draft SER for internal NRC review January, 1982 f.
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Issue NRC's drafi SER to licensee and ACRS
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- Commission review meeting with Staff and licensee g
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- Issue final SER f-y
^y June, 1982 It is also our understanding that the licensee, although not a p
'the Staf f team which performs the integrated assessment and prepares the draf t SER, will be made aware of those deviations to current regulatory criteria which the Staff considers significant and which therefore may require plant and/or K
procedural back-fits during the progress of the integra+ed assessment.
3 As we discussed during our recent meeting, we do not agree wIth the manner in which the reviews of the SER have been scheduled without an appropriate 10 period for Owner review and response to the draft SER prior to ACRS and Commission review. The basic reason for our concern is twofold:
(1) we believe 8111060434 811030 DR ADOCK 05000219 PDR Jersey Central Power & Light Company is a Member of the General Public Utilities System
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accuracy would be improved by Licensee /staf f review prior to submission to ACRS and Commission and (2) we think that it is not possible for the staf f to be adequately knowledgeable in all factors which we understand will be incorporated in any backfit decision. According to the NRC's present plans, these judoements are to be based on such factors as safety significance, practicailty and cost of imp lement ing pl ant modif ications, personnel radiation exposure involved, plant downtime required, and other factors. Based on our experience, the licens?e has j
unique capability including ple't unique knowledge, to make these comparative evaluations. As a result, it is likely that the ACRS and Commission will be presented with a set of SER's which are based on incorrect assessments of the feasibility, radiation exposure and cost of implementation.
The alternative to 1his approach (and one which the SEP Owners understood f rom earlier discuss ions w ith the Staff would be utilized) is to provide a suitable period of time, af ter issuance of the draf t SER and prior to ACRS and Commission review, for review of the NRC findings by the licensee, and resolution of di f f erences between the Staf f and the iIcensee. We belleve that the period required for this review and licensee / Staff interaction is a minimum of six months.
Considering that the SER for SEP represents the culmination of over four years work on the part of both the Staff and the licensee, this amount of time is considered reasonable. In contrast, the present NRC approach in wh.;.
the licensee is expected to review and agree on the need for identified candidates for back-fits in parallel with /.CRS and Commission review, does not provide the time for caref ul and systematic consideration by the plant owner of i
the real impact of such back-fits. SImiIariiy, it is not realistic to expect the licensee to perform these evaluations during the progress of the NRC's integrated assessment on a piece-meal basis.
It is our belief that to undertake ACRS and Commission review prior to agreement on the draft SER conclusions will result in unnecessary confusion and prolong the review process. In addition, the schedule in NUREG 0485 for the completion of the Integrated Assessment appears i
to be overIy optimistic.
We do not have the dedicated resources necessary to support this program as well as all other regulatory required programs (i.e.,
TMl Action Plan - NUREG 0737, Emergency Planning, Environmental Qualification of t
Electrical Equipment etc). We believe that, based on the past experience, the I
schedule for integrated assessment given in the NUREG is too ambitious even for the NRC stat f to accompiish.
l Based on the above, JCP&L requests that ti a NRC revise their plans and schedule for completion of the draf t Oyster Creek SER for the SEP by providing more time for the Integrated Assessment and by adding a 6-month licensee review and evaluation period prior tc ACRS and Commission review.
We will be pleased to discuss this with you in more detail at your convenience.
Very truly yours,
' h [) ( (ll V l
John R. Thorpe, Director j
Licensing & Regulatory Atfairs Ir l
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