ML20039A567

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Discusses Sep,Conduct,Participation & Scheduling for Integrated Assessment to Identify Aspects of Design That Should Be Upgraded
ML20039A567
Person / Time
Site: Oyster Creek
Issue date: 12/14/1981
From: Lainas G
Office of Nuclear Reactor Regulation
To: Finfrock I
JERSEY CENTRAL POWER & LIGHT CO.
References
LSO5-81-12-048, LSO5-81-12-48, NUDOCS 8112180378
Download: ML20039A567 (5)


Text

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o December 14, 1981 Docket No. 50-219 f 2 p LS05 12-048 N

11ECElVED y

Mr. I. R. Finfrock, Jr.

2 DEC171981> ;

Vice President - Jersey Central Power & Light Company

( u n::a n-nn erms T Post Office Box 388 Forked River, New Jersey 08731

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Dear W. Finfrock:

50BJFCY: OYSTEP. CREEK NUCLEAR GENERATING STATION, SYSTEMATIC EVALUATION PROGRAM, CONDUCT, PARTICIPATION, AND SCHEDULING The JCPL/GPU letter (J. R. Thorpe to H. R. Denton) dated October 30, 1981, expressed concern that the schedule for completing the integrated assess-ment for Oyster Creek does not allow for license review and response to the draft integrated assessment report before submission to the ACRS and NRC Commission. Your concern is that without prior licensee review, inac-curate conclusions and backfit recommendations may be presented. You requested that the schedule be extended to provide a six months licensee review period of the draft integrated assessment before ACRS and Comission review.

Before the integrated assessment review is undertaken by the NRC staff, all of the SEP topic reviews should have been completed. The licensee knows the disposition of the topics reviewed. The licensee receives SERs from the staff to review and verify the accuracy of facts contained therein.

In some cases, recommended actions are included in the SERs for the licensee's consideration albeit deferring the need for impleentation to the integrated assessment. Also, a large number of topic assessments are prepared by the licensee which identify differences and potential backfit. Therefore, the licensee is aware of the issues under review by the staff. The only items unknown to the licensee are the staff recommendations concerning implementa-tion of potential backfit items. Since the licensee knows the potential backfit items from individual topic evaluations, the licensee could also evaluate the costs and benefits of potential backfits and reach conclusion f

in parallel with the staff's review.

The current schedule provides a three month interval between the completion of the last topic and completion of the Integrated Plant Safety Assessment Report which will be forwarded to the ACRS and licensee for review. We g$$ N W

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, currently estimate that the ACRS will require two months for their review and coment. Should the licensee take issue with any conclusions presented in the Integrated Plant Safety Assessment Report, they are encouraged to submit their position for staff review. The staff will issue a supplement to the Integrated Plant Safety Assessment Report following ACRS review.

Licensee coments will be considered and if appropriate, incorporated into the supplement. This consideration does not conflict with the integrated assessment schedule.

The purpose of the integrated assessment is to identify aspects of the design of the. facility that should be upgraded and not to approve a final backfit design. It is anticipated that instances could occur where the licensee provides justification at a later date that a backfit is not warranted.

For the reason discussed above, the schedule for completion of these decisions should not be held up for an additional licensee review when, in fact, the licensee has had prior opportunity for review of potential backfit items during the topic review.

Sincerely, Gus C. Lainas Assistant Director for Safety Assessment, Division of Licensing cc: See next page

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currently estimate that the ACRS will require two months for their review and consent. Should the licensee take issue with any conclusions presented In the Integrated Plant Safety Assessment Report, they are encouraged to I

submit their position for staff review. The staff will issue a supplement to the Integrated Plant Safety Assessment Report following ACRS review.

Licensee comments will be considered and if appropriate incorporated into the supplement. This consideration does not conflict with the integrated i

assessment schedule.

The purpose of the integrated assessment is to identify aspects of the design of the facility that should be upgraded and not to approve a final backfit design.

It is anticipated that instances could oocur where the licensee provides justification at a latter date that a backfit is not warranted.

i For the reason discussed above, the schedule for completion of these decisions should not be help up for a additional icensee review, when 3

in fact the licensee has had prior opportunity for review of potential backfit items during the topic review.

Very truly yours, Gus.C. L inas Assistant Director i

for Safety Assessment 4

Division of Licensing cc: See next page 4

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UNITED STATES 8

NUCLEAR REGULATORY COMMISSION 5

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Docket No. 9-219 LS05-81 12-648 Mr. I. R. Finfrock, Jr.

Vice President - Jersey Central Power & Light Company Post Office Box 388 Forked River, New Jersey 08731 J

l

Dear Mr. Finfrock:

SUBJECT:

0YSTER CREEK NUCLEAR GENERATING STATION, SYSTEMATIC EVALUATION PROGRAM, CONDUCT, PARTICIPATION, AND SCHEDULING The JCPL/GPU letter (J. R. Thorpe to H. R. Denton) dated October 30, 1981, expressed concern that the schedule for completing the integrated assess-ment for Oyster Creek does not allow for licenseereview and response to the draft integrated assessment report before submission to the ACRS and NRC Commission.

Your concern is that without prior licensee review, inac-curate conclusions and backfit recommendations may be presented. You requested that the schedule be extended to provide a six months licensee review period of the draft integrated assessment before ACRS and Commission review.

Before the integrated assessment review is undertaken by the NRC staff, all of the SEP topic reviews should have been completed. The licensee knows the disposition of the topics reviewed. The licensee receives SERs from the staff to review and verify the accuracy of facts contained therein.

In some cases, recommended actions are included in the SERs for the licensee's consideration albeit deferring the need for implerientation to the integrated assessment. Also, a large number of topic assessments are prepared by the licensee which identify differences and potential backfit. Therefore, the licensee is aware of the issues under review by the staff. The only items unknown to the licensee are the staff recommendations concerning implementa-tion of potential backfit items. Since the licensee knows the potential backfit items from individual topic evaluations, the licensee could also evaluate the costs and benefits of potential backfits and reach conclusion in parallel with the staff's review.

The current schedule provides a three month interval between the completion of the last topic and completion of the Integrated Plant Safety Assessment Report which will be forwarded to the ACRS and licensee for review. We

-s

~; currently estimate that the ACRS will require two months for their review and comment. Should the licensee take issue with any conclusions presented in the Integrated Plant Safety Assessment Report, they are encouraged to submit their position for staff review. The staff will issue a supplement to the Integrated Plant Safety Assessment Report following ACRS review.

Licensee comments will be considered and if appropriate, incorporated into the supplement. This consideration does not conflict with the integrated assessment schedule.

The purpose of the integrated assessment is to identify aspects of the design of the facility that shculd be upgraded and not to approve a final backfit design.

It is anticipated that instances could occur where the licensee provides justification at a later date that a backfit is not warranted.

For the reason discussed above, the schedule for completion of these decisions should not be held up for an additional licensee review when, in fact, the licensee has had prior opportunity for review of potential backfit items during the topic review.

Sincerely,

)

/ e/(u-

/ us C. Lainas, Assistant Director G

for Safety Assessment f

. Division of Licensing cc: See next page