ML20080H217
| ML20080H217 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/15/1983 |
| From: | Brunner J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20080H220 | List: |
| References | |
| RTR-NUREG-0030, RTR-NUREG-30 ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8309210199 | |
| Download: ML20080H217 (2) | |
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BRAT lCH September 15, 1983 OL/0M Parties
Dear Parties,
Attached please find a proof of service on documents recently sent.
y truly yours, c/Juh.
-w James E Brunner CC OL/0M Service List 8309210199 830915 PDR ADOCK 05000329 G
PDR OC0983-0021A-MP05 N>
Proof of Service This certifies that J E Brunner served copies of the documents referenced in the attached letter, together with the letter, on the following parties by Federal Express Mail, on either September 14 or September 15, 1983!
Mary Sinclair Lynne Bernabei William Paton Judge Harbour Judge Cowan Judge Decker d'lW,".f WL mes E Brunner Attorney for Consumers Power Company OC0983-0021A-MP05
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September 14, 1983 Mr Charles Bechhoefer, Esq Atomic Safety & Licensing Board Panel US Nuclear Regulatory Commission Washington, DC 20555 Dr Frederick P Cowan 6152 N Verde Trail Apt B-125 Boca Raton, FL 33433 Mr Jerry Harbour Atomic Safety & Licensing Board Panel US Nuclear Regulatory Comnission Washington, DC 20555 Dear Board Members In a conference call on August 25, 1983, Chairman Bechhoefer requested a copy of infcrmation supplied by Consumers Power Company as input for the NRC's Yellow Book (NUREG 0030). Attached is the Co=pany's Response to the Chair-r.an's request.
These documents were obtained from a file maintained at the jobsite. My Staff is in the process of attecpting to confirm the completeness of this file.
If a pr-oblem is found, the Board will be advised.
In addition to the requested Yellow Book input data, I have attached, pursuant to the McGuire disclosure standard, certain other documents relevant and caterial to the schedule issue presently before the Board for decision. These documents reflect com=unications between the Company and the NRC's caseload forecast panel.1/
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-mo CD nO 7.g 1/ This is believed to be a relatively co:plete compilation, although a
@8 co=prehensive search of Company files fer caseload forecast panel cor= uni-
-A cations has not been cade. For convenience, the docurents are, for the = cst part, in chronological order, and the Board's copy has been tabbed.
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Of particular interest are the minutes of a July 28-29, 1980, caseload fore-cast panel visit to the jobsite.
See Tab J. K R Kline, August 21, 1980 "NRC Caseload Forecast Panel visit / Schedule Status," Bates 00240-00343.
Some of
~the attachments to these minutes are slides or handcuts used by the Company during the teeting. The meeting was attended by Messrs Hood, Paton, and Mrs Stamiris, among others.
There was discussion at this meeting of the evolution of project schedules after January, 1980, when Forecast 6 was completed. A slide used in the presentation of Mr Mollenkopf (bearing number 00260; see Tab 2 attached to Mr Kline's minutes) lists reasons for the most recent schedule improvement.
See also the attachment with. number 00266, showing a number of items with possible negative impact (i.e. " float") on the new schedule.2/ The NRC Staff esked for and was sent by separate mailing a copy of Mr Mollenkopf's slides (documents 260 to 269), attached to Mr Kline's minute s.
See Tab 3 August 12, 1980 telecon of T J Sullivan, numbered 00237.
I have also provided a copy of the prepared text of Mr Mollenkopf's presentation for this meeting. (document numbered 0611 to 0628)
The caseload forecast panel held a follow-up meeting on August 22, 1980 (see Tab 4, minutes, August 25, 1980, T J Sullivan, 00344). The meeting minutes reflect a frank discussion between CPCo and NRC Staff on bulk installation rates, among other subjects.
On September 16, 1980, the forecast panel announced its conclusion.
See Tab 5, summary of August 25, 1980 meeting on, Licensing Status of the Midland Plant, Units 1 and 2, dated September 16, 1980 by D S Hood. Although the forecast panel's schedule disagreed with the Company's adjusted forecast 6 schedule by three months, the Staff's letter announced that the panel's conclusions were in " reasonable agreement" with the Applic'nt's.3/ These documents and.the yellow books demonstrate that the a
prediction of schedule is an inexact art and that the NRC's caseload panel draws independent conclusions from data presented to it.4/ More importantly, they show that the Company has not misrepresented its schedule to the NRC Staff.5/
Other documents of possible interest or bearing on these issues are attached.
The Company would be happy to respond to any further requests of the hearing Board in relation to this matter.
Very truly yours, L
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J mes E Brunner
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Notes 2/ These mir.utes de=onstrate that the Company's scheduling methodology and the cocpletion dates derived from it were apparently not only revealed ~but also discussed at this meeting-(See notes at p.2 and the attachement at pp 00252-00253).
The Cocpany stated the reason why it thought the schedule could be icproved upon.
It also disclosed significant negative floats (up to six months) associated with sore items (see numbered p 00266 attached to document
- 1) indicating a clear uncertainty in the revised schedule and the need for improvements to achieve it.'
3/ Of course the reasonableness of the target fuel load date is not an icsue before the Board.
4/ See also, e.g., memo to T R Tourtellote from Roger S Boyd dated March 7, 1978 numbered 00001..
5/ See also, minutes of a June 13, 1980 meeting relative to NRC review of the Midland OL application (doc 00234 et seq).
(These notes were authcred by J E Brunner. No privilege is claimed regarding these notes, which merely recite what happened at a public eeeting attended by a number of other attorneys and other persons. The disclosure of the notes does nct waive any applicable privileges regarding other notes or com=unications of Mr Brunner.
Further, see D S Hood's notice of the June 13, 1980 eeeting, doc 0607-0610.
OC09E3-0016A-Mf04
I OM/0L SERVICE LIST Mr Frank J Kelley, Esq Atomic Safety & Licensing Attorney General of the Appeal Board State of Michigan U S Nuclear Regulatory Commission Ms Carole Steinberg, Esq Washington, DC 20555 Assistant Attorney General Environmental Protection Division Mr C R Stephens (3) 720 Law Building Chief, Docketing & Services Lansing, MI 48913 U S Nuclear Regulatory Commission Office of the Secretary Washington, DC 20555 Mr Myron M Cherry, Esq Suite 3700 Ms Mary Sinclair Three First National Plaza 5711 Summerset Street Chicago, IL 60602 Midland, MI 48640 Mr Wendell H Marshall Mr William D Paton, Esq RFD 10 Counsel for the NRC Staff Midland, M1 48640 U S Nuclear Regulatory Commission Washinrjon, DC 20555 Mr Charles Bechhoefer, Esq Atomic Safety & Licensing Atomi: Safety & Licensing Board Panel Board Panel U S Nuclear Regulatory Commission U S Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr Frederick P Cowan Ms Barbara Stamiris 6152 N Verde Trail 5795 North River Road Apt B-125 Rt 3 Boca Raton, FL 33433 Freeland, MI 48623 Mr Fred Williams Mr Jerry Harbour Isham, Lincoln & Beale Atomic Safety & Licensing 1120 Connecticut Avenue, NW, Suite 325 Board Panel Washington, DC 20036 U S Nuclear Regulatory Commission Washington, DC 20555 Mr James E Brunner, Esq Mr M I Miller, Esq Consumers Power Company Isham, Lincoln & Beale 212 West hichigan Avenue Three First Natioaal Plaza Jackson, MI 49201 52nd Floor Chicago, Il 60602 Mr D F Judd Mr John Demeester, Esq Babcock & Wilcox Dow Chemical Building PO Box 1260 Michigan Division Lynchburg, VA 24505 Midland, MI 48640 Mr Steve Gadler, Esq Ms Lynne Bernabei 2120 Carter Avenue Government Accountability Project St Paul, MN 55108 1901 Q Street, NW Washington, DC 20009 9/3/83 miO583-0429a100