ML20005A163

Protests Size of Util Financial Commitment in Absence of Any Indication by NRC That Wood & Haven Sites Have Some Future Potential.Early Site Review Should Not Require Detailed Environ Studies

ML20005A163
Person / Time
Site:	05000502, 05000503, 05000504, 05000505, 05000506, 05000507
Issue date:	03/08/1976
From:	Burstein S WISCONSIN ELECTRIC POWER CO.
To:	Rusche B Office of Nuclear Reactor Regulation
Shared Package
ML20005A158	List: ML20005A159 ML20005A163
References
NUDOCS 8106290465
Download: ML20005A163 (3)

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Mr. Benard C. Rusche, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C. 20555

Dear Mr. Rusche:

ALTERNATIVE AND FUTURE SITES WISCCNSIN UTILITIES PROJECT DOCKETS STN 50-502 THRCUGH 50-507 On August 15, 1975, Wisconsin Electric Pcwer Ccmpany, Wiscensin Pcwer and Light Ccmpany, Wisconsin Public Service Corporation, and Madison Gas and Electric Ccmpany (Applicants) submitted Site Addenda and Environmental Reports for the Wocd and Haven sites. These dccuments were submitted .n response to, and in accordance with, Mr. Giambusso's letter and attachments thereto dated August 24, 1974, which requested general siting information en potential future sites. The submittals also were made in the context of the Ccmmission's announcement on March 11, 1974 of its intended policy for early site reviews.

Mr. Boyd's letter to the App 11 ants dated. January 9, 1976, transmitted requests for additional information for the Wccd and Haven Environmental Reports and Site Addenda. These requests for additional information extend well beycnd the requirements indicated in Mr. Giambusso's letter and in the

.'d. arch 11, 1974 policy anncuncement. They are ackncwledged to be based en current regulatcry guidance and regulations for cons = ction permit applica:icn review.

The major benefit of an early site review fer a potential applicant, for the NRC, and for the public is to fetermine whether significant safety or er onmental concerns may exist which could preclude the future use a site fer construction of a nuclear plant. This early si: 3 teview unavcidably must be based on majcr safety and environmental aspects cf the site, assuming a hypothetical or standard nuclear plant with specified scurce terms is to be cons:::cted en the site at scme future time.

Mr. Benard C. Rusche March 8, 1976 In the absence cf specific Nuclear Regulatory Ccmmission guidance for early site review, the Applicants in this instance formulated general guidelines based on our understanding of the Commission's intent. As an example, our guidance assumes an early site review can be conducted in the absence of specific schedule dates for construction and operation, detailed cost-benefit studies, and justification of the need for power. Further, we believe the concept of early site review does not require detailed environmental and geotechnical studies beyond those necessary to define adequately major site characteristics. For.

example, Question 340.1 attached to Mr. Boyd's January 9 letter states that Section 1 of the Envirormental Report is deficient in that it does not presently demonstrate the need for 1800 MW of electric power generation. Obviously for early site review where no construction schedule has been established it is not possible to ecmplete Section 1 in the detail required for a Constructicn Permit Application. Similarly, Questions AR 324.8 through AR 324.13 refer to specific design details of man-made dikes and slopes.

It is apparent frem Mr. Boyd's letter of January 9, and the enclosures thereto, that the Weed and Haven Environmental

, Repcrts and Site Addenda submitted for early site review by the Nuclear Regulatory Ccmmission have ac~ually been reviewed in accordance with Construction Permit i formation requirements , and even in accordance with guidelines beyond those in effect at the-tine that Koshkonong was decketed. We have been required to expend in excess of $25 million in _ support of the Koshkonong Nuclear Plant applications before federal and state agencies to date, and we have not yet begun the required public hearings necessary prior to the issuance of construction authorications. We believe that it is not the Ccmmission's intent that potential applicants for nuclear power plants shculd be required to invest millions of dollars in detailed studies to obtain an indication from the ccmmission that a particular site has potential for future nuclear plant construction. To require Constructicn Permit detail in the early site review step, in cur opinion, defeats the purpose and intent of the early site review.

We new estimate that additional ex=enditures in excess of $1 million wculd be required to provide the additicnal information requested by the NRC staff for the Wecd and Haven reviews. We are currently evaluating whether it would be prudent to ccmmit these substantial sums of monev in the absence of any indication by the staff that either, er Ecth, of these sites h' ave scme future potential. We are also evaluating the desirability of attempting tc respend to requests for additicnal infcrmation in the absence of specific Ccmmission guidelines for early site review. Accordingly, we are presently unable to provide ycu with a schedule for cur response to Mr. Scyd's letter of January 9.

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Mr. Benard C. Rusche March 8, 1976 We believe that it would be to our mutual interest to review this matter with you. Accordingly, we wculd be pleased to meet with you and members of your staff to discuss cur present submittal, the staff raquest for additional information, and guidelines appropriate for early nuclear plant site reviews.

Very truly yours,

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XMecutive Vice President Sol Burstein 9

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