ML19327C049

Responds to & Documents Discussion of Various Issues Raised During 891024 Visit to Plant.Util Fully Aware of NRC Requirements & Obligation

ML19327C049
Person / Time
Site:	Oyster Creek
Issue date:	11/02/1989
From:	Long R GENERAL PUBLIC UTILITIES CORP.
To:	Mcmahon A NEW JERSEY, STATE OF
References
C-89-759, C000-89-0759, NUDOCS 8911150157
Download: ML19327C049 (2)

Text

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I OPU Nesteet CeeperoWen One Upper Ponc Road i

er Parsippany, Nem, lersey 070$4 i

201 316 7000 TELEX 136 482 l

Wrlier's Direct Dial Number; j

i November 2, 1989 l

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C000-89-0759 j

o A. J. McMahon, Acting Director J

Division of Environmental Quality Department. of Environmental Protection State of New Jersey CN 027, Trenton, NJ 08626-0027 j

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Dear Mr. McMahon:

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This is in response to your letter of October 19, 1989 and documents our discussion ~of the various issues during your visit to the Oyster Creek Nuclear Generating Station on October 24, 1989.

-The implication from the statement in your letter that *...GPU Nuclear (GPUN) t does not feel there is a rieed to meet certain Nuclear Regulatory Commission (NRC) licensing requirements...' does not represent our view.

I don't know how i

you came to believe it, but it just isn't so.

GPUN has always and does today

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recognize that it must meet all NRC requirements under our license.

This is l

clearly stated and emphasited in our Mission, Values, Polices and Procedures.

We (as other licensecs) do discuss with the NRC their requirements and where i

appropriate and acceptable to the NRC, seek clarifications, exemptions or exceptions that are warranted for the specific conditions at CCNGS.

NPC requirements for the OCNGS recognize and incorporate any such specific items.

The margin of safety for the OCNGS is essentially captured in the Final Safety Analysis Report and Technical Specifications where the facility licensing bases i

s and operating limits are contained.

The licensing requirements were established during the initial licensing process and have been revised, as appropriate, to incorporate evolutionary issues that develop in the regulatory process.

Your thought that *...there is a wide divergence between GPUN meeting NRC requirements for a full term operating license...and actually proving that the plant has an adequate margin of safety in 1989.', appears not to recognize that the license is a dynamic document that is modified when relevant issues arise. As stated above, GPUK operates the plant within the requirements of the license thus ensuring that the margin of safety for the plant is maintained.

8911150157 691102 Opol l

PDR ADOCK 05000219 P

PDC r

GPU Nuclear Corporation is a subsid.ary of Generat Public UtMties Corporation

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'A.

J. McMahon, Acting Director f

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Department of Environmental Protection i

November 2, 1989 Page 2 i

As you recognise at any given time there may be a nunber of open issues which are the subject of discussion with the NRC.

The NRC has chosen in the Full Term Operating License process to address the Systematic Evaluation Program, 1

NUREG-0737 and Environmental Impact Statement issues and bring these issues to closure as part of the process.

For open issues that have been determined to j

have significant inpact on the plant and corporate resources, GPUN utilises the Long Range Planning Program (LRPP) to manage these items. Both issues identified by the NRC (e.g. GL 88-01 concerning intergranular stress corrosion

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eracking) and issues identified by GPUN to enhance plant safety and reliability are addressed by the LRPP.

This program was developed to assess, coordinate j

and schedule major work tasks of projects at the OCNGS, including those mandated or proposed by the NRC.

The LRPP and resultant plan / schedule are license conditions, and, as a result, receive NRC review and approval. Open l

NRC issues that have not yet been identified as having a significant impact on i

the plant (e.g. Individual Plant Examination), are the subject of correspondence and periodic meetings with the NRC.

Consequently, timely resolution of open issues is mutually agreed upon by GPUN and NRC.

We appreciated the opportunity to meet with you and your staff on October 24, 1989 and believe these meetings serve to increase the communication between our organisations and would hope they continue. Further, as the result of this meeting, it is our understanding that you intend to request that the NRC hold a t

public meeting with respect to the FTOL process.

Acknowledging this intent, CPUN believes that the NRC should be given latitude as to the forum of this meeting.

Should NRC agree to host a public meeting, GPUN would fully support

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and participate as requested.

Ver ' tru

yours,

)

1

(/s )

• fM.

R. L. Long Vice President a.74 Director Planning and Nuclear Safety RLL/ctb (OCNGS)

S cc Nr. William T. Russell, Administrator Region I t

U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 g ocument Control Desk j

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U.S. Nuclear Regulatory Commission Mail Station PI-137 Washington, D.C.

20555

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