ML20093C025

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Advises of 1-month Delay in Meeting R Tedesco 811214 Schedule in Support of Facility Hearing & Review.Viable Schedule Must Recognize Need for Iteration W/Applicant Following Each Significant Submittal
ML20093C025
Person / Time
Site: Midland
Issue date: 12/28/1981
From: Vollmer R
Office of Nuclear Reactor Regulation
To: Eisenhut D
Office of Nuclear Reactor Regulation
Shared Package
ML19258A087 List: ... further results
References
CON-BX16-074, CON-BX16-74, FOIA-84-96 NUDOCS 8201220049
Download: ML20093C025 (3)


Text

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NUCLEAR REGULATORY COMMISSION r

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WASHWGTON D.C.20086

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  • M December 28, 1981 b4 E x

6 MEMORANDUM FOR: Darrell Eisenhut, Director l

Division of Licensing FROM:

Richard H. Vollmer, Director Division of Engineering

SUBJECT:

MIDLAND-DESUPPORhFORREVIEW0FREMEDIALACTIONS i

AND HEARING j

By memorandum,. dated December *14. 1981,. Robert.Tedesco transmitted a schedule j

for the numerous actions necessary.to. support a hearing. schedule consistent with the applicant's. predicted construction start. dates. We can support this

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j schedule in principle and have already moved to gain additional resources for HGEB by contract 7.nd for SEB by revising assignments.to'make an additional structural engineer available for the term of the hearing.-

In addition, we are delaying transfer of the MEB reviewer to the ACRS until.

March. Despite this action, the schedule as proposed for HEB input will have to slip approximately one month.

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The schedule as currently proposed, is optimistic to a fault. The underlying assumption that the applicant will submit completely acceptable material on i

the established.date for.each action is. belied by the record.to date. The applicant is moving.on many fronts and. undertaking remedial actions that are well outside the usual scope of construction activities for nuclear power plants.

As a result, his submittals are frequently.both incomplete and controversial 4

with regard to normal engineering practice.

r This flaw in the scheduling philosophy is particularly acute because of the l l-highly compressed nature of the review process and the complex interactions between the various construction activities. The result of a small number I

of applicant delays at the front end of the process will be a cascade of changes.that will cause overlaps. and further compress the staff review I

time, e.g., a reviewer required by schedu.le to be writing testimony on h

one subject while he is in. fact. attending the hearings for an earlier subject. *he confusion that could ensue will render the schedule useless and demonsv ate that it is in fact no schedule at all.

In my opinion, a hidle schedule.for this review must recognize the need for-at least one iteration with.the applicant following each.significant submittal.

If we choose to proceed on a less realistic schedule, I believe that preserva-tion of our resources will demand that each applicant's delay.be imediately

. assessed with regard to the overall schedule and.that commensurate. schedule revisions be prepared by the Project Manager on.a continuing basis..The attached. memorandum from J. Knight indicates that the first such delay may have occurred.

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D. Eisenhut 1 1,

DE.will use all available resources to help preserve the schedule.. We 1

have arranged for ETEC.to put extra help on this job an'd to work over.the j

holides. Even so, you should.be aware,.and make Consumers aware, that any del y or lack of complete and acceptable submittals by them will likely cause a schedule breakdown.

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Richard H. Vollmer, Director Division of Engineering l

Attachment:

i As stated

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H. Denton E. Case R. Tedesco J. Knight

-l E. Adensam D. Hood.

R. Bosnak G. Lear i

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