ML20050D586
| ML20050D586 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 04/07/1982 |
| From: | Shields S PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| PSI-NRC-0012, PSI-NRC-12, NUDOCS 8204120342 | |
| Download: ML20050D586 (2) | |
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, April 7, 1982 I
Senior Vice President -
PSI /NRC-0012 l
Nuclear Division
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Mr. Harold R. Denton, Director Docket Nos.:
STN 50-546 4
Of fice of Nuclear Reactor Regulation STN 50-547 U.S. Nuclear Regulatory Commission Construction Permit Nos.:
Wa shing ton, D.C.
20555 CPPR-170 1
CPPR-171 MARBLE HILL NUCLEAR GENERATING STATION UNITS 1 AND 2
Dear Mr. Denton:
On Thursday, March 18, 1982, the Rule to Require Applicants to Evaluate Differences from the Standard Review Plan was published in 47 Fed. Reg.
1 11651. This rule, as stated, would apply to the Marble Hill operating license application.
Public Service Company of Indiana, Inc. (PSI) hereby requests that Marble Hill, as a replicate of the previously reviewed and approved Byron j
Station, be exempted from this rule for the reasons discussed in this letter.
i On November 3,1975, the Nuclear Regulatory Commission (NRC) approved the Byron /Braidwood design for replication at Marble Hill.
As a replicate design, only unique portions of the Marble Hill design were to be subject to a separate NRC review. This concept was to carry through to the completion of i
the operating license review for the base plant and the replicate plant. One of the conditions of the NRC's approval was that PSI " hold design changes to an absolute minimum". This criterion has been met through the expenditure of much time and effort by PSI.
It is PSI's understanding that the NRC Staff, as recently as the February and March,1982, at Advisory Committee on Reactor Safeguards (ACRS) meetings to review Byron, reaffirmed its intent to allow I
replication of units by referencing the Byron Safety Evaluation Report in fut ure replicate (Marble Hill) or duplicate (Braidwood) unit Safety Evaluation Reports.
Since the NRC Staf f reviewed and approved the vast majority of the Marble Hill design when it reviewed and approved the Byron design, little or no benefit can be gained by PSI evaluating dif ferences from the Standard Review Plan (SRP) acceptance criteria.
I It should also be noted that the design of Marble Hill's Nuclear Steam Supply System as defined in RESAR-3 will be reviewed by the NRC Staff for Northeast I
QOO S
Ib 8204120342 820407 i
PDR ADOCK 05000546 A
PDR P. O. Box 190, New Washington, Indiana 47162 812. 289.1000 1
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.4 PUBUC SERVICE INDIANA Mr. Harold R. Denton April 7, 1982 PSI /NRC-0012 Nuclear Energy, Millstone, Unit 3; Texas Utilities, Commanche Peak; Duke Power, Catawba; Commonwealth Edison, Byron /Braidwood; Public Service New Hampshire, Seabrook; Union Electric, Callaway; and Kansas Gas & Electric, Wolf Creek operating license applications prior to the review of the Marble Hill operating license application. Again, little can be accomplished by evaluating SRP deviations on such already well reviewed material.
The Chairman of the Commission, the Honorable Nunzio J. Palladino, in his October 5,1981, speech at the Edison Electric Institute Financial Conference,
" Perspectives on the Regulation of Nuclear Power... a Time for Action," made the point that review of applications should be streamlined by standardization of entire plant design. This is the fundamental reason behind replication and further review of replicate portions of the Marble Hill design is contrary to this goal.
As of March, 1982, the Marble Hill Final Safety Analysis Report (FSAR) has been under preparation for over a year. Almost all first drafts of the document have been prepared and/or reviewed. The timing of this preparation coincides with PSI's intent to file an operating license application in December, 1982. Requiring PSI to evaluate the Marble Hill design for deviations from the SRP will seriously impact PSI's intended filing date and subsequent licensing schedule.
In summary, it is PSI's position that application of the new rule to Marble Hill would be contrary to the Commission's long standing commitment to replication in the review of the Marble Hill application.
In view of the advanced stage of Marble Hill FSAR preparation your response is requested by April 27, 1982. Members of my staff or I will be happy to discuss this matter further with you at your convenience.
Sincerely, S. W. Shields SWS/TDG/kdh cc: D. G. Eisenhut R. L. Tedesco B. J. Youngblood B. L. Doolittle J. G. Kernier J. E. Konklin J. J. Harrison L