ML20039G540
| ML20039G540 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/11/1982 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| TASK-***, TASK-TM NUDOCS 8201180395 | |
| Download: ML20039G540 (8) | |
Text
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GPU Nuclear GU U
ear 100 Interpace Parkway Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Wnter's Direct Dial Numbec h' %
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January 11, 1982 9
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Mr. D. G. Eisenhut 3#y Director 3
. C;. j'k Division of Licensing 0
Office of Nuclear Reactor Regulation S/
U.S. Nuclear Regulatory Commission
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Washington, D. C.
20555
Dear Mr. Eisenhut:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Systematic Evaluation Program (SEP)
Your letter cf November 27, 1981 requested that our senior management attend a meeting with other SEP licensee senior management and NRC management on December 17, 1981 and commented on the schedule and quality of our SEP submittals.
Our representatives attended the meeting and were very pleased with the results. However, we believe that certain statements in your letter concerning schedule and quality of our SER submittals could lead to an erroneous evaluation of the status of the program.
Our specific comments on your letter are as follows:
1.
The NRC accounting of topic assessment completions discussed in the letter and the licensee submittal summary attached thereto are not consistent and nre misleading.
For example, the licensee submittal summary graph shows that JCPSL has submitted only one topic assessment. The letter also indicates that eighteen additional topic assessments remain to be completed.
In fact, JCPSL has transmitted a total of 35 topic assessments since re-direction of the SEP in February, 1981, and has a total of only six additional topics remaining to be submitted. The actual number of topic assessment submittals by JCPSL is shown in the attached graph and in Enclosure 1.
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GPU Nuclear is a part of the General Pubhc Utihties System j
9 2.
The NRC Ictter of November 27, 1981, refers only to topic assessments as a measure of JCPSL's contribution to the SEP. As shown in Enclosure 1, in the period from April through December, 1981, alone, JCP6L has prepared and submitted fifteen seismic analyses and has responded to other NRC transmittals. This is in addition to the substantial effort which has been. expended in obtaining and transmitting information in responseto NRC (and NRC contractor) telephone requests.
3.
NRC comments regarding the quality of topic assessments prepared by JCPSL have been directed primarily to the Design Basis Event (DBE) topics.
In this regard, the following should be noted:
o The_JCP6L DBE topic assessments submited in May, 1981, were the first assessments submitted by any licensee and followed directly a draft topic assessment for Oyster Creek provided for guidance by the NRC staff.
o Despite JCPGL requests for feedback on these topic assessments, there was no meeting in July to discuss Oyster Creek DBE assessments and no NRC questions were received by telecopy in July, 1981, as indicated in the NRC letter of November 27, 1981.
- Instead, JCP6L has received one set of questions by telecopy in October, 1981, and additional questions on the DBE assessments from the NRC in a telephone call on July 30, 1981, a aceting on August 13, 1981, and most recently, in a conference call on November 25, 1981.
All have been answered with the exception of the questions received from the NRC (Mr. Wagner) in October, 1981 on which JCP6L is awaiting clarification.
4.
Re-submittal of eleven revised topic assessments by JCPSL (which the NRC letter implies is required and notes that re-submittal schedules were not provided) has never been requested by the NRC nor committed to by JCP6L.
In fact, in a meeting on August 13, 1981, the NRC advised JCPSL that the topic assessments submitted by JCPGL in bby 1981, would not be returned for revision and re-submittal by JCP6L; instead, the NRC would incorporate additional information to be provided by JCPSL and issue them as final topic assessments. This direction to JCPSL was confirmed in NRC letter to JCP6L dated August 20, 1981.
As a result, the number of topic assessments owed by JCP6L is not eighteen, but eighteen less the eleven revised assessments referred to above, less one topic transmit,tal'~s,'
on December 15, 1981, for a total of six topic assessments.
WebelievethatthesesummariesindicatethatJCPGLhaskbeendilligentj s
in its' support of SEP
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t Overall SEP schedule (including dates for conpletion of topic SER's, start of integrated assessment, ACRS/ Commission review,. completion of SER) are and always have.been set by_the NRC.
We have repeatedly expressed concern that the schedule is overly optimistic and does not adequately l
provide for owner interaction (particularly after draft SER issuance and ACRS/ Commission reviews). As indicated in our October 30, 1981 letter, we believe that a sufficient period (at least 6 months) is needed for Owner /
.NRC staff review, interaction and resolution prior to submittal of integrated assessment' report to ACRS/ Commission.
We were pleased with youe statement near the end of the December 17 meeting to the effect that the SEP owners were to be complimented for their efforts. We will also followup shortly on your request at the meeting for j
recommendations to make the final Oyster Creek plant integrated assessment as meaningful and complete as possible.
Very truly yours, c
d w
Philipgl. Clark L-)
Executive Vice President 1r 2
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DECEMBER 14, 1981
SUMMARY
OF SER STATUS FOR OYSTER CREEK l
I.
TOPICS WHICH ARE GENERIC, DELETE 0, NOT APPLICABLE 59 II.
COMPLETED TOPIC SERS WHICH ARE NRC RESPONSIBILITY A.
DRAFTS COMPLETE 12 B.
FINALS COMPLETE j((
33 III.
COMPLETED TOPIC SERS WHICH ARE GPUN RESPONSIBILITY
- A.
DRAFTS SUBMITTED 30 B.
FINALS RETURNED TO GPUN
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35
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IV.
TOPICS STILL UNDER EVALUATION A.
BY GPUN 6
B..
BY NRC 4
10
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137 COMPLETION STATUS (% OF 137)
O COMPLETE (DRAFT OR FINAL), GENERIC, DELETED, MA - 93%
0 COMPLETE (FINAL ONLY), GENERIC, DELETED, NA -
62%
Originally to be NRC responsibility.
Re-assigned to GPUN as part of re-direction in February 1981.
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GPUN PERFORMANCE ON SER SUBMITTALS SER COMMITTED ACTUAL SUBMITTALS DATE SUBMITTAL DATE 1.
GPUN Ictter 2/4/81 committed to submit 20 draft SERs.
June 30, 1981 Actual Submittals:
II-1A May 7, 1981 II-1B May 7, 1981 II-1C May 7, 1981 II-4A May 7, 1981 II-4B May 7, 1981 II-4C May 7, 1981 II-3A May 7, 1981 II-3B May 7, 1981 II-3.B.1 May 7, 1981 II-3C May 7, 1981 III-2 May 7, 1981 III-3A May 7, 1981 III-4D May 7, 1981 XV-1 May 7, 1981 XV-3 May 7, 1981 XV-4 May 7, 1981 XV-5 May 7, 1981 XV-7 May 7, 1981 XV-9 May 7, 1981 XV-11 May 7, 1981 XV-13 May 7, 1981 XV-14 May 7, 1981 XV-15 May 7, 1981 XV-18 May 7, 1981 XV-19 May 7, 1981 XV-20 May 7, 1981
SER COMMITTED ACTUAL SUBMITTALS DATE SUBMITTAL DATE 2.
GPUN letter 8/13/81 committed to submit the following draft SERS (subject to workload for other NRC required submittals)
Il-2C 9/30/81 11/4/81 III-3C 9/1/81 11/4/81 111-70 9/1/81 11/4/81 V-5 9/15/81 11/4/81 V-12A 9/1'/81 11/4/81 VI-1
.10/30/81 VI-7C 9/30/81 IX-1 1 mo. after NRC Lead Topic III-4A 9/30/81 III-4B 9/30/81.
12/7/81
'III-4C Early 82, based on NRC Lead topic by 11/81 II-4D 10/15/81 12/15/81 II-4F 10/15/81 11/4/81 XV-16 9/1/81 11/4/81 IX-5 12/31/81, based on NRC Lead Topic by 11/30/81 O
3.
In addition, GPUN provided additional information 'or comments on indicated SERs by transmittals of:
XV-7 8/25/81 XV-1 11/4/81 XV-2 11/4/81 XV-3 11/4/81 XV-4 11/4/81 XV-9 11/4/81 XV-11 11/4/81 XV-13 11/4/81 XV-14 11/4/81 XV-15 11/4/81 XV-19 11/4/81 II-1A 11/30/81 II-1B 11/30/81 II-1C 11/30/81 III-1
- 11/30/81 III-5A 11/12/81 III-5B 10/6/80 9/30/81 i
V-5 11/4/81 VI-4 4/9/81 VII-2 8/17/81 IX-3 10/1/81 4
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In parallel with the above, GPUN has prepared and submitted numerous seismic analyses / evaluations in 1981.
These include:
Evaluation Date submitted 0
ESW Pump Structural Evaluation 6/81 0
ESW Pump Functional Evaluation 12/10/81 0
Emergency Condenser Foundation Bolts 10/19/81 0
Containment Spray HX Foundation 9/2/81 0
Recirc Pump Support Analysis 9/2/81 0
Response to NRC Questions on Recirc Pump Analysis 10/19/81 0
Re-analysis of Recirc Pump Supports 11/24/81 0
Effect of Valve Operators on Piping Stresses Analysis for 6, 8, 10-inch 8/24/79 Analysis for 2, 4-inch 12/79 Re-analysis (PIPESD) for 2, 8-inch 12/10/81 0
CRD Hydraulic Control Units Preliminary Analysis 5/7/81 Final Analysis.
10/19/81 and 11/24/81 1
0 CRD Small B. ore Piping Analysis In progress Reported 10/19/81 0
Reactor Vessel Support Analysis 8/24/79, 12/21/79 and 10/19/81 0
Elec. Equipment Anchorage Analysis 7/81 0
Evaluation of NRC Analyses of CRD and MS Piping 9/2/81 0
Analysis of Condensate Storage Tank In progress, Reported 10/19/81
.