ML19327C049

Responds to 891019 Ltr & 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)

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I OPU Nesteet CeeperoWen er One Upper Ponc Road Parsippany, Nem, lersey 070$4 201 316 7000 i

i TELEX 136 482 l Wrlier's Direct Dial Number; j i

November 2, 1989 l

?. C000-89-0759 I o j A. J. McMahon, Acting Director l J

Division of Environmental Quality Department. of Environmental Protection State of New Jersey ,

CN 027, Trenton, NJ 08626-0027 j m  ;

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Dear Mr. McMahon:

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, I 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  ;

s Analysis Report and Technical Specifications where the facility licensing bases i 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  !

PDR ADOCK 05000219 l 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 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 {

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 (

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 j gDocument Control Desk ,

l U.S. Nuclear Regulatory Commission Mail Station PI-137 Washington, D.C. 20555

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