ML20126G824

Provides List of Issues & Some Discussion Covering Employee, Regulatory,Technical,Operations/Maint,Equipment Aging & Economic Factors Which Need to Be Considered to Establish Bases Upon Which Nuclear Power Plants Can Operate Safely

ML20126G824
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/17/1992
From:	Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML20126G806	List: ML20126G803 ML20126G824
References
NUDOCS 9301040249
Download: ML20126G824 (5)

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POWERING cwnmvare wiar Ml0NGAN'S PROGRESS Genevel OfMes 212 West Mn.tugan A<enue. Jackson. MI 49201 * (5th 7881111 December 17, 1992 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Tom:

Recently, the Big Rock Point Nuclear Plant celebrated its 3"

h year of operation.

During that time, and with appropriate rsight by the NRC, the Plant has provided safe and economic energy and has contributed greatly to numerous R&D issues for the nuclear industry.

Since Big Rock does not intend to operate beyond its current operating license date of May 31, 2000, it seems appropriate that the pattern for policy making for opera-tions until "end of licensed life" can be served, once again through the joint efforts of Coacumers Power Company-(CPCo) and the NRC making use of Big Rock Point (BRP).

Such a program would not only assist CPCo and the NRC in planning their respective future operations but would perhaps more importantly, provide guidance to utilities which might need to consider early shut-down.

It is with this in mind that-CPCo has solicited NRC staff ideas and suggestions on how we mir 5t jointly proceed on this important undertaking.

We are comaitted to working with the NRC

-to establish the bases upon which our nation's nuclear plants can continue to operate safely, economically and with a predictable process for approaching end of license.

Following is a list of issues and some discussion ou each, covering employee, regulatory, techaical,. operations / maintenance, equipment aging, and.osonomic factors which need to be consid-

-ered.

.End-of License for Bia Rock To date, no commercial r2 clear plant in the United States has been operated throughout the full-term of its operating license..

Although there have been a number of premature nuclear plant shutdown announcements during the recent past and cther plant rhutdowns are being considered, most plants are currently plan-ning to operate to either the end of their current operating license or to the end of an extended operating license.

In-addition-to providing the NRC and utility industry with a regula-tory model for these full term plant operations, Big Rock's operation until end of license (EOL) will provide valuable l

information regarding retention of adequately skilled staff, 9301040249 921230' DR-ADOCK 0500 0

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Ldealing with. aging equipment operation.and maintenance, as well 6

as extending the commercial value to the community.

Also, this will instill confidence-that operating until'end of license is indeed achievable, thereby. engaging much needed public and investment community support.

To this end, BRP will not be operated beyond its current.end of licenso date of May 31, 2000.

A Joint NRC/CPCo Effort at BRP Increased NRC involvement with CPCo in its efforts to operate BRP to end of licenso can provide needed reassurance to the-public that DRP is safely operated until ECL.

This joint effort will afford the NRC the opportunity to evaluate firsthand the trade-offs routinely encountered by most nuclear utilities.

It would afford CPCo the opportunity to experience the perspective of the NRC in its deliberations on matters such as regulatory compliance, generic letters, waivers and new regulations.

With the perspective of the NRC, CPCo could pursue a plan to end-of license, which would maximize the "best bang for the buck" in maintaining plant safety.

This would permit a better_ regulatory assessment and the cost of regulation potentially promoting a reduction in cost while' maintaining adequate. safety.

This would be formalized as part of our Integrated Living-Schedule.

The Roles of the Reaion and NRR In some way, the use of NRC Region and NRR persons-directly assigned to BRP end of license operation could play a large part-1 in the day-to-day regulatory oversight.

It_would seem that the a

process for NRC design / operation review of BRP_ activities could be expedited and made more efficient by an appropriately. defined

. project team comprised of seasoned NRR, Region and'CPCo. person--

nel.

Such a project team _would have.the specific focus of safe and economic operation'for the last five years of plant opera-tions.

Eher utility suonort The !!RC has the unique vantage point of _ factoring the perti-

t. ant experience of other licensees into solving day-to-day BRP operating and maintenance issues.- Such solutions might include having other utility representatives participate in areas where they may.have; specific skills _to apply.- The NRC-could act as the clearing house for identifying unique experiences with other-licensees that might. improve EOL ope ations.

Bia Rock Ootion Study A Big Rock Option Study is currc.. sly-being reviewed by CPCo Officers..Within_the-study, many assumptionc were made concern-ing plant decommissioning, low-level radwaste storage and the need for on-site spent fuel storage.

The assistance of the NRC in-reviewing these assumptions and perhaps reducing the.uncer-taint!.es would be very helpful to CPCo, its customers and its shareholders.

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Michinan Public Service Commission (MPSC)

There is no doubt that the Michigan Public service Commission holds CPCo accountable for the safe operation of BRP.

However, as representing the interests of CPCo's customers, the MPSC must exercise diligent oversight for the cost of energy production at BRP and CPCo's other generating stations.

It would be a rare opportunity for the NRC to take part in the many deliberations associated with achieving the lowest cost for safe and reliable operation of BRP.

Our staffs have discussed the potential uniqueness of manag-ing BRP to end of license.

They have developed an outline (attached) for detailed plans to support the needs of both licensee and regulator for BRP end of license.

I would suggest that we request that our respective staffs prepare a joint presentation for our review on this subject before the and of May 1993.

Yours very truly, th'

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Frederick W.

Buckman FWB/mfa CC:

JColvin, NUMARC DPHoffman, CPCo u

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ATTACHMENT.

BRP END-OF-LICENSE PLAN EXECUTIVE

SUMMARY

As Big Rock Point nears the end of license (EOL), efforts must be refocused to maintain and operate the plant safely and economically. ; Current regulation and industry practices stress operational excellence without weighing the~

I cost, or asking "what is the right thing to do?" This philosophy requires O

revision as the plant ages.

Therefore, it is necessary to develop a plan to address the most cost effective way to assure safe plant operation.

Efforts have begun with the NRC to build a consensus for appropriate EOL actions and regulations.

DISCUSSION 1

Action items were identified to address EOL concerns.

It should be recognized.

j that the following " plans" will be developed and will require continued

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maintenance.

Human Resource Plan Address personnel considerations to assure a qualified-staff is maintained until EOL.

Involves EKZienert, MDBaurassa, BRP HR Committee and Corporate Human Resources, whoas purpose will be to provide necessary input to an existing BRP committee.

-Public Relations Plan.

Address the public concerns that EOL rcgulation does not make the plant any; less safe.

In addition, to instill confidence the public will be informed-

about the future decommissioning process,-..volves TDPetroskey,fCEMacInnis, BABrogan, NRR and Region III.

. Decommissioning Plan l-Even though regulations _are already in place, decommissioning;is central ~to" l

any EOL plan.

This plan will address the method chosen;for. decommissioning-

-and its significant impact on the other-plansLdescribed'herein.

Involves; JSRang, RJAlexander, and NRR Decommissioning Branch.

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. Enhance the Interrated Plan L

-The~" enhancement" is expected to include NRC participation in.the' current.

plan.

Thisl participation should help prioritize~workloadfand; assist in'the management of aging issues:end all other issues-that_have significant resource impact. -Involves CCWithrow, PRA (CRBoss, BABrogan). NRR and Region.III.

i Develon NRC Regulatory Focus L

i This' plan is expected! to be managed.mostly by the. NRC with input from BRP Licensing. -Interaction with the " Financial" regulator is also-expected tof occur as-this plan is' implemented.

4 These_five plans _will need early management support to belimplemented by1the J end:of 19931 to : ensure. a timely solution' to the_ EOL. challenge.

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FtFWZJtstS Jackson MI 49201-2277 mKnstW5 Pet 06 Lass Dr. Thomas E. Murley, Director.

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 s

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