ML19327C049
| 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 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 ;
i
Dear Mr. McMahon:
l
, 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
(
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 !
r GPU Nuclear Corporation is a subsid.ary of Generat Public UtMties Corporation
.o' ,
= . '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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