ML20065M479

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Submits Addl Comments on SEP Phase Ii.During Final Stages of Sep,Nrc Properly & Effectively Assessed Safety Intent of SRPs & Evaluated Merits of Alternative Proposals
ML20065M479
Person / Time
Site: Oyster Creek
Issue date: 10/18/1982
From: Phyllis Clark
GENERAL PUBLIC UTILITIES CORP.
To: Crutchfield D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8210210280
Download: ML20065M479 (2)


Text

. o GPU Nuclear NQQIQ[ 100 Interpace Parkway Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Writer's Direct Dial Number:

October 18, 1982 Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Crutchfield :

SUBJECT:

Oyster Creek Nuclear Generating Station License No. DPR-16 Docket No. 50-219 Systematic Evaluation Program (SEP)

Your letter of July 14, 1982 requested that we provide comments on SEP Phase II. By letter dated August 16, 1982, we provided you with our comments on the program. Those comments reflected our experiences up to that date. Since that time, there has been considerable progress made in completing the SEP evaluation of Oyster Creek; and we feel it is appropriate at this time to provide additional comments.

Our comments are as follows:

1. An original objective of the SEP program was to provide for balanced decision making with regard to backfits; through the ef forts of the SEP Branch Staff, significant headway has been made in this area. With input from our Staff, a concerted effort was made to evaluate any potential backfit taking into consideration: risk, cost, personnel exposure, schedules, and relative priorities. We feel this effort was effective for the SEP items.

However, while the SEP Branch Staff did try to factor in the impact on Oyster Creek of other regulatory requirements (NUREG 0737, Appendix R, Heavy Loads, 10CFR50.48, Equipment Qualification, Emergency Planning, etc.), they could not prioritize any of those issues thereby reducing the effectiveness of the integration /prioritization process.

2. In our previous letter, we had commented on the NRC Staff reviewers inflexibility with regard to prescriptively applying the Standard Review Plans (SRPS). Based on recent experience, we withdraw that comment.

We believe that during the final stages of the Program the SEP Staff properly 9210210280 821018 /gh PDR ADOCK 05000219 PDR f p

GPU Nuclear is a part of the General Public Utilities System

SystemItic Evaluation Progrem (SEP)

Page 2 October 18, 1982 and effectively assessed the safety intent of the Standard Review Plans and  ;

evaluated our alternative proposals on their own merits. In general, we feel that the intetration process that was applied to the Oyster Creek SEP topic assessment was effective in evaluating those areas where Oyster Creek differed from the SRP.

The comments provided by our August 16, 1982 letter, except as noted above, are still considered appropriate.

In the event that you should have any questions or wish to discuss this matter further, please contact Mr. J. Knubel at (201) 299-2264.

Very truly yours,

$b.

P. R. Clark Executive Vice President Pk cc: Ronald C. Haynes, Administrator Region I U.S. Nuclear . Regulatory Commission 631 Park Avenue King of Prussia, PA 19405 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731

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