ML20125A791

Ack Receipt of Ltr Commenting on 790613 Meeting Re Industry Efforts Related to TMI Accident

ML20125A791
Person / Time
Site:	Comanche Peak
Issue date:	08/01/1979
From:	Harold Denton Office of Nuclear Reactor Regulation
To:	Fikar L TEXAS UTILITIES CO.
References
NUDOCS 7908170351
Download: ML20125A791 (2)

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' AUG 1 1979 Mr. L. F. Fikar Executive Vice President Texas Utilities Services, Inc.

2031 Eryan Tower Dallas, Texas 75201 Ocar Pr. Fikar:

Thank you for your letter comenting on my meeting with utility representatives on June 13, 1919, and for attending that meeting. I am enclosing a meeting stimary for your records.

Despite your interpretation of my coments, I am appreciative of the extensive ongoing efforts related to the Three Mile Island Unit 2 accident by the industry.

My coments at the meeting were directed at failure of the industry to provide unsolicited information, coments and suggestions useful in the evaluation of the Three Mlle Island accident and in the formulation of a program to prevent and/or mitigate Accidents of a similar nature in other nbClear power plants.

It is gratifying to Icarn of your Comanche Peak Design Review Team. You and we are dedicated to the prevention of another serious nuclear power plant accident.

To that end, we hope you will keep us advised of the deliberations and conclu-sions of the Cesign Review Team as their work progresses. We will be happy to mmt with your group for a mutual exchange of information at appropriate mile-stones in our respective studies. An exchange of this nature would be respon-sive to my coments at the meeting as discussed above.

We like your proposal to anticipate and respond to Round Tm Questions from the staf f by reviewing other dockets and interfacing with the Project Manager. I have directed W. Burwell to work with your representatives to reap full bene-fits from that course of action. Also, we suggest that you review the Safety Evaluation Reports and Supplements for plants similar to Comanche Peak. In the past, we have experienced an inordinate length of time in resolving the out-standing itms listed in the Safety Evaluation Reports. Many of these itms are generic to a type of reactor, nuclear steam system supplier or architect-engineer. Early resolution of these items can provide a substantial shortening of the review period.

In addition, three intervenor groups have been admitted to the hearing on the Comanche Peak operating license. Although the contentions have not been finalized, we should recognize that time must be provided for the conduct of the hearing. To that end, we urge you to give attention to the early resolu-tion of those matters which are related in any way to the contested issues to be heard before the Atomic Safety Licensing Board. Our regulations permit the

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p. .,. ,,,3 start of a hearing on contested issues when the staff and the Mvisory Comittee on Reactor Safeguards have completed their reviews on these matters. Thus, we may petition the Atomic Safety 1.icensing Board to start the safety hearing shortly af ter the Mvisory Comittee on Reactor Safeguards issues its report ,

although our safety review might not be Complete for other matters. We Wuld consider this action only if we have reason to believe that the remaining out-standing ituas could be resolved on a schedule which would maintain continuity in the conduct of the hearing.

You r.av have my assurance that we will do all within our capabilities to license Cmnche Teak and other nuclear stations when th?y are reedy for fuel loading.

We are continuing our efforts to augment our tachnical resources. We have recently completed a reassignme.rt of some technical mee.bers from ether offices within the ibclear Regulatory Comission. Some ci these individuo1s have been assigned to the impacted review branches Withfd the Division of Systo,s Safety.

Others have gone to the Systematic Evaluation Program, releasing experienced review.ers to return to their casework review. In addition, he are finalizing arrangefdents to establish review trams of specialists at the national laboratories.

Finally, we have initiated a strong 'ecruttr:ent drive to increase our ter:nanent staff as rapidly as possible in those specialties where our resources have been in chronic short supply.

I understand your recomendation that I should retain the permanent resources for casework and use the interim personnel for our Three Elle Island task force a ssignr.cnts . Unfortunately, I cannot fully agree. k* hen ihree Mile Island occurred we quickly mobilf zevi the available staff. These were largely caseverk rev iewa rs . They were there, they know what happened, they have longstanding work relationships with each other, and they know the scope of staff review within the ibclear Regulatory Comission prior to the ac ident. In short, their education is complete. In my view, we would waste a large effort educating the interim staff before they would be effective on the task forces during the period these groups are making decisions that evolve frm the Three Mile Island accident.

Homver. the intent of your suggestion is well taken. During the period in which we are implementing the decisions that evolve, I will be returning the permanent casemrk reviewer to their base assignment at the earliast practt-cable date.

In closing, I would like to say that our goal is to return the licensing reviews to the schedules which c.t!sted prior to the Three Mlle Island accident. We will ccnttunue to work with industry towed that goal.

Sincerely, 1r k Harold R. Denton, Directer Office of Nuchar Reactor Regulation Enclosare:

Sumary of Meeting to Discuss Casewrk !chedules Cated Jul y 2,19 79

5 TEXAS UTILITIES SERVICES INC.

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. . . . . .'. . '. l.".'.7. . ,, June 22, 1979 Dr. liarold B. Denton Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Coc::sission Washington, D.C. 20555

Dear llarold:

The emeting which you held on June 13 with utility representatives to discuss your probicas associated with uanagment of Staf f resources in the wake of the experience at Three Mile Island was discouraging and frustrating.

You expressed your view that industry was not responding affirmatively to benefit from the 1MI experience but was merely waiting to react to instructions from the NRC in view of the lessons learned from that experience. Frankly, it was shocking to learn that you were not aware of the ongoing broad ef forts by industry to evaluate the TMI experience, such as the detailed studies being performed by the Edison Electric Institute and the Electric Power Research Institute. I am certain that your Staf f is well aware of these ef fe rts, and suggest that you have your Staf f brief you on the scope and status of them.

It was less shocking that you are not aware of the efforts undertaken by Texas Utilities to study and benefit from the TMI experience. As I noted at the meeting, we had not briefed you on our ef forts because we considered your involvement directly with TM1 matters to be of higher importance. In any event, this will advise you that Texas Utilities established a Comanche Peak Design Review Team in April to review and check all design criteria, saf ety related systems, and operating procedures in light of the TMI experience.

The Design Review Team consists of senior engineers and officials responsible for the design construction and operation of Comanche Peak. The Director of the Center for Energy Studies and Chairman of the Department of Electrical Engineering at the University of Texas also is a member of the Team. The Team reports directly to the Chairman of the Board of Texas Utilities Company.

In addition to the independent in-house review of Comanche Peak in light of the Ut1 experience, the Team also will cooperate and interface with the EEI, EPRt.

and NRC, and will utilize the information generated by those bodies in the Comanche Peak review.

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Dr. liarold B. Danton Jun2 22, 1979

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- regard to the discussion of your management / resource proble=.

including the new priorities for Staff review and the realignment of Staf f resources, we appreciated the opportunity to hear your thoughts and pro-vide you with ours. It seems fair to characterize the sense of utility ma nagement in attendance as complete dissatisfaction with your proposed course of action to solve the problem. As pointed out to you, we all agree that as a manager you have a serious staffing problem but you have no alternative but to get the resources at this stage which would avoid the suspension of Staff reviews (particularly for operating licenses such as Comanche Peak) and thereby avoid the inevitable costs in the billions of dollars to the industry and the American public which vill result from your proposal.

In large measure, electrical energy shortfalls associated with delays in operation of nuclear power reactors resulting f rom your proposal would be tilled by oil-fired energy. This would necessitate the use of hundreds of thousands of barrels of oil per day and thereby exacerbate the already critical shortage of oil in this country. In this regard, you are no doubt aware of the sober presentation made to the Coasission on June 14, 1979, by the Federal Energy Regulatory Commission and others relating to the pending operating license for salem-2, and the costs of replace =ent energy f rom oil-fired units if Sale =-2 is not licensed.

As I stated at the meeting last week, we believe that your proposal is si= ply unacceptable, and will do whatever is necessary internally with-in Texas Utilities with the Congress, or elsewhere to allow you to modify your proposal in favor of a less costly aid adverse approach. I interpreted f rom your reaction to our meeting that you also are concerned about the serious L,plications of your proposal, and would welcome efforts to facilitate a retreat from that proposal. Accordingly, we are pursuing through appropriate channels methods by which your manage =ent/ resources problem can be resolved. In addition, we vill continue to attempt to develop ideas which eight solve that probl e=, and will co==unicate any such ideas to you.

Specifically with respect to Comanche Peak, I would like to explore with you how Texas Utilities and the Staf f can cooperate to eliminate or signif icant-ly reduce the possibility for delay in issuance of the operating license. I have a specific proposal which in xj view will eliminate a cajor cause for delay in Staf f review of the Comanche Peak license applications--the largely unnecessar .

formality of Staf f questions and utility ansvers. We believe thit we can ant ici;tn approximately three-quarters of the questions which the Staf f vill ask in Round Two for Comanche Peak by reviewing other dockets and interf acing with th; Sta:f Project Manager. We propose to so anticipate the Staf f que<t ions, and t - proviJ.

co=plete FSAR information in a timely f ashion without receiving ' o r t.a 1 Round Two questions. This should in large measure eliminate the duplicative Staff efforts required routinely for the review of applications in order to gener ate Round Twc questions. Of course, since we likely will not anticipate all quest iens there may be a need for a greatly reduced question-and-answer phase.

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Dr. P.arold B. Denton Juna 22, 1979 In order to assure that our ef forts to anticipate and respond f ully to the Staff's need for information are fruitful, we would appreciate an assurance that you will allocate the Staff resources necessary to assure that the Staf f will be prepared to license Comanche Peak for operation when that facility is ready for fuel loading. I and my staff are pre-pared to meet with you and your Staf f to discuss or formalize these ce==ituents. I would appreciate your prompt response to this proposal so that we may start our efforts as soon as possible.

Finally, we appreciate your assurance that you will keep us advised by written =csoranda every few weeks as to the status of your broader efforts to resolve this problem. We understand ar.d are encouraged to learn that you have been successful in obtaining a coemitment from the Idaho National Engineering Laboratory to supply 40 or 50 technical support personnel for your interim Staff requirements. We hope that your continued ef forts to locate necessary assistance will be as successf ul. In this re-gard, I reiterate the suggestion made last week that you should retain your present reviewers on licensing matters, and utilize the interim personnel for TMI task force matters. In my view, this would provide far greater ef ficiency and continuity in utilization of Staf f resources, yet would assure that the necessary expertise is available for both licensing and TMI activities.

Sincerely.

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