ML20098A029

Statement of Position.Notifies That GE Has Significant Interest in Proceeding & Administration of Commission Licensing & Regulatory Program

ML20098A029
Person / Time
Site:	Oyster Creek
Issue date:	01/04/1965
From:	Maher E GENERAL ELECTRIC CO.
To:
Shared Package
ML20097K095	List: ML20098A023 ML20098A029 ML20098A138 ML20098A140 ML20098A165 ML20098A175
References
FOIA-95-258 NUDOCS 9509180072
Download: ML20098A029 (3)

Text

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- D UNITED STATES OF AMERICA OF $N O gp ATOMIC ENERGY COMMISSION

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) Docket No. 50-219 JERSEY CENTRAL POWER & LIGHT COMPANY ) ,

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STATEMENT OF POSITION Ehe Cqy >

General Electric Company is the contractor for Jersey Central Power and Light Company for the design and construction of the Oyster Creek nuclear power plant. General Electric is also engaged in the manufacture and sale generally of boiling water nuclear power plants, nuclear boilers, and nuclear fuel. For both of these reasons General Electric has a significant interest in this proceeding and in the admin-istration of the Commission's licensing and regulatory program.

It is General Electric's position that for the reasons stated in the Petition for Review and accompanying Brief of the AEC Regulatory Staff and in the applicant's Reply thereto, the Initial Decision and Order of the Atomic Safety and Licensing Board is in error in its requirement for the submittal to the Board of additional information and design  !

i details, particularly those relating to the core design, as a condition upon the provisional construction permit. The Board's error involves a misconception of what is necessary or prac ticable in terms of the 1

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. > e level of development of design details for a project ~ such as Oyster

' Creek at the construction permit stage of the Commission's licensing process. 'As applicant has noted, the conditions upon the provisional' construction permit flowing from this error would add a burdensome complexity to that process in'the instant case.

The Board's Initial Decision and Order could have far-reaching and disturbing implications for the future administration of the Com-mission's regulatory program. General Electric is entirely confident that, if necessary, the conditions upon the provisional construction permit imposed by the Board in this case can and will be met. But the requirement for the submittal of this information and data to the Board constituted to review the application for a construction permit is unnecessary. Existing procedures, including ACRS and Staff Review, and the necessity to qualify for an operating license, fully protect the interests of the public, the Commission, and the industry in the safety of nuclear plants.

Further review of design details by the construction permit Board would be a distortion of the regulatory and licensing program contemplated by the Act and the Commission's regulations which, as a precedent, could have serious adverse effects on the Commission's regulatory program. General Electric does not believe such a change

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t l in existing procedure is either necessary or desirable. If this~ change  !

j. is to be made, however, it should not be effected by.a Board decision 3 but by changes in regulations upon which all interested members of the industry could be heard in advance.

i For the foregoing reasons, General Electric Company respect-

) fully requests the Commission to:

9 (1) Accept this Statement of Position in this proceeding.

l (2) Grant the Regulatory Staff's Petition for Review. l l- (3) Permit Ge neral Electric, in the event the Petition for  ;

Review is so granted, to file a brief within the period l-4 specified for filing a reply brief, and to participate otherwise as may be appropriate, upon the Com-mission's review of the Board's Initial Decision and Order.

Respectfully submitted, GENERAL ELECTRIC COMPANY By_ [ . .

u E. T. Maher, Counsel Atomic Power Equipment Dept.

175 Curtner Avenue San Jose, California Dated at San Jose, California this 4th day of January,1965.

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