ML19347B818
| ML19347B818 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/14/1980 |
| From: | Steptoe P COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML17193A131 | List: |
| References | |
| NUDOCS 8010160036 | |
| Download: ML19347B818 (4) | |
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In the Matter of
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COMMONWEALTH EDISON COMPANY
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Docket No. 50-10
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Dresden Nuclear Power Station,)
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Unit 1
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1 (Environmental Qualification) )
PETITION FOR EXEMPTION 2
4 Commonwealth Edison Company ( " Commonwealth") holds NRC operating license DPR-2 relating to Dresden Nuclear Power Station, Unit 1, located in Grundy County, Illinois.
4 In 1978 Dresden Unit 1 was shut down for certain safety i
backfits and chemical cleaning.
In 1980 Commonwealth decided to defer restart of Dresden Unit 1 due to present uncertainties regarding requirements arising from the accident at Three Mile Island and frcm the NRC's Systematic Evaluation Program, 3
l and because of existing corporate short-term cash flow deficiencies.
Commonwealth has brought to a hal all engineering and construction activities related to Dresd'en Unit 1,'other than the chemical cleaning project, which has been maintained in a state of readiness pending NRC approval.
However, it l
appears that Commonwealth needs Commission approval to delay i
environmental qualification of Dresden Unit 1 electrical i
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equipment.
Commonwealth now applies for such approval in this Petition For Exemption, pursuant to 10 CFR S50.12(a).
On May 23, 1980 the' Commission entered a Memorandum
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and Order in respect of a " Petition For Emergency and Remedial
. Action" filed by the Union'of Concerned Scientists.
CLI 21, 11 NRC 707 (1980).
In that Memorandum and Order the Commission set certain deadlines for Staff review and com-pletion of environmental qualification of all safety-related g
equipment in all-operating plants.
See 11 NRC at 714-174.
l In a letter dated August 8, 1980 from D. Crutchfield to l
D.
Peoples the NRC Staff informed Commonwealth that not-withstanding the deferral of restart of Dresden Unit 1 until l
1986, the Staff was unable to allow any delay in the Ccmmi-ssion's Schedule for resolution of the environmental quali-fication issue.
However, the Staff advised Commonwealth that Commonwealth could petition the Commission for an exemption from the qualification deadlines b.e Exhibit A).
On August 29, 1980 and again in revised form on September 19, 1980 the Staff issued orders, immediately effective, requiring the submission of all environmental qualification information in respect of Dresden Unit 1 no later than November 1, 1980.
(See Exhibit B).
Pursuant to 10 CFR 550.12, Commonwealth requests the Commission to allow Commonwealth to delay environmentally -_
4 qualifying the electrical equipment for Dresden Unit 1 i
until restart of the facility.
As the attached affidavit of Neil P.
Smith (Exhibit C) shows, there is no nuclear fuel 4
i in the reactor vessel or in the reactor building, and there-fore there is no chance of a nuclear-related accident requiring the operation of Dresdent-Unit one's electrical equipment in i
a hostile environment.
Moreover, allowing Commonwealth to J
k defer environmental qualification for Dresden Unit 1 will result in significant economic savings to the Company in a 1
4 period of financial difficulty and will allow Commonwealth to devote additional resources to environmentally qualifying safety-related equipment at the Company's other operating reactors.
For these reasons this request meets the standards j
f set forth in 10 CFR 550.12 (a).
I In addition, Commonwealth requests the Commission to stay the effectiveness of the Staff's " Revised Order For Modification of License" dated September 19, 1980 (Exhibit i
i B), which requires Commonwealth to submit environmental qualification information by November 1, 1980.
While Common-wealth has, for defensive purposes, contemporaneously with this Petition for Exemption requested a hearing in respect i
of this Revised Order, we believe it would be simpler, more appropriate, and less of a drain on the Ccmmission's resources if a hearing before a licensing board could be avoided by 1
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the Commission taking prompt action both to grant Comon-if
! wealth's Petition for Exemption from the environmental e
qualification deadlines set forth in the Commission's Memorandum and Order of May 23, 1980 and to excuse the i
Company from the Staff's related November 1, 1980 deadline i
f for the submission of information.
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Respectfully submitted, 4
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One oflthe Attorneys 1
for Commonwealth Edison Company 1
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ISHAM, LINCOLN & BEALE i
Suite 4200 1
One First National Plaza Chicago, Illinois 60603 312) 558-7500
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EXHIBIT A
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August 8, 1980 Docket No. 50-10 Mr. D. Louis Peoples LD f P 0
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Director of Nuclear Licensing l Jh g'
Comonwealth Edison Company Post Of fice Sox 767 Chicago, Illinois 60690
Dear Mr. Peoples:
RE: EriVIROZiENTAL QUALIFICAT10ii 0F ELECTRICAL EQUIPMEiii
References:
(1) March 28, 1920 letter from Dennis L. Ziemann t.o D. L. Peoples (2) May 1,1980 letter from Robert F. Janecek to. Denni s L. Zie...a nn (3) May 6,1930 letter from D. L. Peoples to Paul W. O'Connor In a previous letter (Ref.1) we requested that certain containment related inforcation either be provided or referenced by May 1,1980. This request, part of the accelerated environmental qualification (E.Q.) review, was to obtain inf;rration that cculc :e used in cefining equipment's post-incident service environrent.
In lieu of providing the information requested, ycu stated (Ref. 2) that submittal of this information at a later date would be more ap;ro:ri ate.
Ycu indicated that the Dresden Unit I clant was currently shutdown for an extenced period uncergoing a ruor retrofit program macifying both the e?.ergency core cooling and reactor protection systems.
In acdition, to the hardnare cocifications, you stated that new analyses of core cahavior and new operating procedures were to be developed.
As a result, responses to our request would be forthcoming as these tasks were cc pleted.
The Corr.ission's Memorancum and Order of May 23, 1930 provided a schedule for coroletion of the environmental qualification reviews of ill facilities.
Although respenses to our recuest mignt be more accurately acdressed curing the _later stages of the retrofitting effcrt, we find that the retrofit schedule is not cor.catible with the Commission's scnecJle. Ihis letter is to inform you that Dresden Unit I will not be hanaled any differently than any other SEP plant.
You should submit the requested information on a schedule ccm atible with our EQ needs.
Should ycu believe this is not an appropriate schedule, you may exercise your option to ;ietition the Ccc ;issica for an exemption from the requirements provided in the May 23,19EG Greer.
Sincerely, f' O. 5 b [
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[b Dennis M. Crutchfield, Chief Operating Reac. ors Brancn d 1
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Division of Operating P.eactors U
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4 UNITED STATES Exhibit B 8
NUCLEAF. REGULATORY COMMISSION
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%,,,,. #g September 19, 1980 Docket Nos. 50-10 and 50-237 Mr. J. S. Abel Director of Nuclear Licensing Cocinonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690
Dear Mr. Hoffman:
SUBJECT:
ENVIRONMENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT (DRESDEN NUCLEAR POWER STATION UNIT N05.1 AND 2)
The Orders for Modification of License dated August 29, 1980, contained incorrect references. We have accordingly revised the Orders.
In view of this revision, the date for which a hearing may be requested is also accordingly revised.
Sincerely, Darrell G. Eisenhut, Director Division of Licensing
Enclosures:
1.
Revised Order -
Dresden Unit No.1 2.
Revised Order -
Drescen Unit No. 2 cc w/ enclosures:
See next page A ),z ? b ja i
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a Mr. J. S. Abel September 19, 1980 cc w/ enclosure:
Isham, Lincoln & Beale Department of Public Health Counselors at Law ATTN:
Chief, Division of One First National Plaza, 42nd Floor Nuclear Safety Chicago, Illinois 60603 535 West Jefferson Springfield, Illinois 62761 Mr. B. B. Stephenson Plant Superintendent Director, Technical Assessment Dresden Nuclear Power Stat on Division i
Rural Route #1 Office of Radiation Programs Morris, Illinois 60450 (AW-459)
U. 5. Environmental Protection Agency Natural Resources Defense Council Crystal Mall #2 917 15th Street, N. W.
Arlington, Virginia 20460 Washington, D. C.
20005 U. S. Environmental Protection U. S. Nuclear Regulatory Commission Agency Resident Inspectors Office Federal Activities Branch Dresden Station Region V Office RR r1 ATTN:
EIS COORDINATOR Morris, Illinois 60450 230 South Oearborn Street Chicago, Illinois 60604 Susan N. Sekular Assistant Attorney General Resident inspector Environmental Control Division Drescen Nuclear Power Station 188 W. Randolph Street c/o U. S. NRC Suite 2315 Rural Route #1 Chicago, Illinois 60601 Morris, Illinois 60450 Morris Public Library 604 Liberty Street Morris, Illinois 60451 Chai rman Board of Supervisors of Gruncy County Grunay County Courtnouse Morris, Illinois 60450 C
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UNITED STATES OF AMERICA i
j NUCLEAR REGULATORY COMMISSION
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In the Matter of Comonwealth Edison )
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Company
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Dresden Nuclear Power Station,
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Docket No. 50-10 Unit No.1
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1 REVISED ORDER FOR MODIFICATION OF LICENSE I.
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Comonwealth Edison Company (the licensee) is the holder of Facility Operating l
License No. OPR-2, which authorizes the operation of the Dresden Nuclear Power i
l Station, Unit No. I at steacy-state reactor power levels not in excess of I
700 megawatts thermal (rated power). The facility consists of a boiling water reactor located at the licensee's site i.n Grundy County, Illinois.
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II.
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On November 4,1977, the Union of Concerned Scientists (UCS) filed with the Comission a " Petition for Emergency and Remedial Relief " The i
petition sought acticn in two areas; fire protection for electrical cables, and environmental qualification of electrical components. By i
Memorancum and Order dated April 13,1978 (7 NRC 400), the Comission 1
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denied certain aspects of the petition and, with respect to other aspects, l
ordered tne NRC staff to take several related actions.
UCS filed a o.
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9 1978.
By Mercrancum and Order, 5 p e
on DUPLICATE DOCUMENT Entire document previously entered into system under:
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No. of pages:
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