ML20198E004

Comments on Safety Sys Functional Insp Approach.Insp Will Place Burden on Licensee Due to Intensiveness & Time Needed

ML20198E004
Person / Time
Site:	Oyster Creek
Issue date:	05/19/1986
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	Zwolinski J Office of Nuclear Reactor Regulation
References
NUDOCS 8605270178
Download: ML20198E004 (2)

Text

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GPU Nuclear Corporation i -

Nuclear

== 388 Forked River, New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

May 19, 1986 Mr. John A. Zwolinski, Director BWR Project Directorate #1 f0.J/7 Division of BWR Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Oyster Creek Nuclear Generating Station Infomal Coments Safety System Functional Inspection Approach As requested in your note dated April 16, 1986, we have reviewed the subject inspection approach.

This type of inspection is a very intensive review of a particular safety system integrating numerous review areas.

Inspections of this scope require significant resources from the NRC staff as well as the licensee.

The guidance provided places a great deal of the burden on the licensee to assemble detailed

analysis, design, procurement, implementation, and testing documentation.

The licensee, especially those with older plants, would be required to dedicate significant personnel and monetary resources.

The proposed inspection guidance severely underestimates the time required by the licensee to compile the necessary documentation for the review.

The guidance stipulates a two week prior notification.

Documentation needed for the review must be compiled by various corporate and site departments and will in all likelihood require some procurement through the AE/NSSS vendors.

These activities will require a minimum of four weeks, if all goes well, and more likely a period of two months will be requireo.

In order to be responsive to the inspection effort, it would be helpful if the inspection team developed a list of the documentation they would expect to review.

Additionally, much of the documentation concerning design, safety analysis, and acceptability has been previously submitted and reviewed by the NRC in various programs (i.e.,

FSAR licensing review, fire protection, SEP, environmental qualification, etc.).

Prior review of this documentation, which is currently on the docket, would better define the scope of the inspection effort for the NRC inspectors as well as decreasing the impact on the licensee.

Historically, inspections of this type have resulted in the expenditure of significant resources on the part of the licensee to resubmit to the inspectors documentation which is currently available on the docket.

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GPU Nuclear Corporation is a subsidiary of the General Public Utihties Corporation

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SAFETY. SYSTEM FUNCTIONAL INSPECTION APPROACH PAGE 2:

i Specifically, the following comments are provided for your consideration in developing the Safety System Functional Inspection guidance:

Comment #1 The licensee should be given a two-month advance notice of the proposed inspection including. identification of the system being inspected, identification of the inspection team, and a list of documentation to be reviewed during the inspection.

Comment #2 The inspection team should review previously docketed information (i.e.,

FSAR, SEP, fire protection, 50.59 reports, generic safety issues, etc.) to define the scope of the inspection' effort.

(Note:

Contact with the NRC Project Manager would be helpful in identifying past and current activity regarding the system to be inspected.)

Comment #3 The inspection team should conduct daily briefings with licensee cognizant personnel to identify questions, concerns, or informational needs which will allow the licensee to develop additional information/ documentation to resolve. issues as they occur.

This will provide a more meaningful inspection report for both the NRC and the licensee.

Comment #4 Week 3 of the inspection is provided for the licensee to compile additional documentation requested by the inspection team.

One week would be sufficient provided the additional documentation is available in the l

corporate office on at the site location; however, should it be necessary to obtain such documentation from outside sources additional time would be i

required (2-3 weeks).

l I - hope these comments are of use to you and if you should have any questions please contact Mr. Joseph Kowalski, Oyster Creek Licensing Manager at ;(609)917-4643.

Very truly yours, Vice President and Director Oyster Creek PBF/GB/ dam 6

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