ML20049J588

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Summarizes Util Response to ASLB 820226 Order.Responses Were Provided During 820210 Telcon
ML20049J588
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 03/11/1982
From: Fitzgibbons R
ISHAM, LINCOLN & BEALE
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8203180427
Download: ML20049J588 (3)


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COUNSELORS A' LAW ONE FIRST NATIONAL PLAZA CHICAGO,ILLINOl5 60003 08 YT COLN.

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WILLIAM G BEALE, tas5-191t3 SUITE 440 WASHINGTON, D.C.20035 co L:

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March 11, 1982

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Before the Atomic Safety and Licensing Board,

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su n the Matter of

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Docket Nos. 50-254-SP-COMMONWEALTH EDISON COMPANY

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50-265-SP (Quad Cities Station,

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(Spent Fuel Pool Modification)

Units 1 and 2)

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Dear Administrative Judges:

This letter summarizes Commonwealth Edison Com-pany's

(" Commonwealth Edison") responses to the Atomic Safety and Licensing Board's

(" Licensing Board") " Order (Notice of Telephone Conference Call)," dated February 26, 1982, which responses were provided during the conference call conducted on Wednesday, March 10.

Board Question Number 1 Commonwealth Edison's application is now complete, except for written response to the NRC Staff's two questions-concerning the " rigging mechanism" to be used in the reracking operation.

Written responses tc 5.hese two questions are expected to be mailed to the NRC Staff by Friday, March 12, 1982.

The~ application will then be complete.

Board Question Number 2 Summary of the answer to this question is to be supplied by the NRC Staff.

i Board Question Number 3 Commonwealth Edison has outstanding to Intervenors interrogatories and a request for document production.

In B203100427 820311 PDR ADOCK 05000254 I g G

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. the interest of proceeding to hearing in early May, Common-wealth Edison is willing to waive its right to insist on responses to the remainder of the outstanding interrogatories and the request for document production, provided Intervenors give Commonwealth Edison sufficient advance notice of any witnesses they intend to call at the hearing and allow Commonwealth Edison the opportunity to take the intended witnesses' depositions.

Intervenors have informally requested Commonwealth Edison to provide various material.

This material has been provided, with two exceptions.

First, Intervenors have requested information which has been designated proprietary by the manufacturer of the proposed racks.

Now that the Licensing Board has entered the Stipulated Protective Agreement, this information will be provided.

Second, Intervenors have requested some material related to Common-wealth Edison's workers' occupational exposure to radiation.

This material has now been located and will be provided to Intervenors.

Board Question Number 4 Commonwealth Edison has no objections to the with-drawal of Contested Contentions Nos. 1-4 and 7.

Board Question Number 5 Prior to the conference call conducted on Wednesday, March 10, Commonwealth Edison was unaware of any intention on the part of Intervenors to request withdrawal of any additional contentions.

The contentions currently remaining at issue for which Intervenors have not requested withdrawal are Nos. 5 (occupational exposure), 6 (bowing), 8 (quality assurance) and 9 (seismic structural adequacy).

Board Question Number 6 To minimize disruption of activities at the Quad Cities Nuclear Station, licensing authority to install at least six new high density racks must be received between the middle of June and the first of July.

The reracking operation can still be accomodated without having to install eight racks of the currently authorized design, as set forth in the letter to the Licensing Board dated November 16, 1981, provided licensing authority to install the new high

, density racks is obtained between the middle of July and the first of August.

If licensing authority is not received by the first of August, Commonwealth Edison will have to install eight racks of the currently authorized design in the Quad Cities spent fuel pools to maintain full core discharge capability.

As noted in the November 16, 1981 letter to the Licensing Board, the alternative of installing eight racks of the design currently utilized at the Quad Cities Nuclear Station is not satisfactory to Commonwealth Edison.

Board Question Number 7 Commonwealth Edison will be prepared to commence the hearing in this proceeding the second week of May.

We believe the duration of the hearing will depend on the extent of limited apoearance statements and cross-examina-tion of Commonwealth Edison witnesses and whether Intervenors intend to call their own witnesses, but anticipate that the hearing will last no more than three days.

Respectfully submitted, i

4 Robert G J'itzg4)pns JrQ RGF:emc cc:

Service List L.

Woldrige, Commonwealth Edison D.

Stahl P. Steptoe